ML20151G713

Emergency Operating Instruction Procedures Generation Package

ML20151G713
Person / Time
Site:	Browns Ferry
Issue date:	07/20/1988
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20151G711	List: ML20151G708 ML20151G713
References
PROC-880720, NUDOCS 8807290165
Download: ML20151G713 (378)

Text

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l BROWNS FERRY NUCLEAR PLANT I

EMERGENCY OPERATING INSTRUCTION' PROCEDURES GENERATION PACKAGE (PGP)

REVISION 001

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i Page 1 of 378 8807290165 080720 PDR ADOCK 050C0259-p PNU

TABLE OF CONTENTS SECTION ,

PAGE I Introduction 3 II Plant' Specific Tcchnical Guidelines 4

- PSTG Development 6

- E0I Development 9 III E0I Writers Guide 14 IV E0I Verification Program 15 V E0I Validation Program 20 VI E0I Training Program 27 ATTACHMENTS I Plant Specific. Technical Guidelines 34 II Writers Guide for Emergency Operating Instructions 103 III Deviations Cross Reference Document 129 IV Response to NRC TER Comments 370 r

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INTRODUCTION l

The purpose of this Procedures Generation Package is to supplement the Procedures Generation Package submitted June 22, 1984. The reasons for this second submittal tre as follows:

Transmit an updated set of Plant Specific Technical Guidelines (PSTGs) which include addition of all items from Revision 3 of the generic Emergency Procedure Guidelines which were previously not included in the PSTGs. This includes material relating to Anticipated Transient Without Scram (ATWS) events, Secondary Containment Control, and Radioactivity Release Control.

Describe the programs that will be used to verify and validate the E0Is. This verification and validation (V & V) will be done on the entire procedure, not just the new material.

Describe the program that will be used to train the operators on the new guidelines and handle any changes in the E0Is that are made as a result of the updated PSTGs and the new writers guide.

Included in this submittal are three attachments; the Browns Ferry PSTGs, the E0I Writers Guide, and the Deviations Cross Reference Document.

The Browns Ferry E0Is are developed directly from the Plant Specific Technical Guidelines and are written in accordance with the E0I Writers Guide. The E0Is are verified and validated in accordanca with the E0I Verification and Validation programs. Existing E0I training is and'will continue to be ongoing with training on new or updated material taking place upon completion of, or in parallel with, verification and validation of that material.

Future changes to the PSTGs will be reviewed and brought to the attention of the NRC in accordance with 10CFR50.59.

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PLANT SPECIFIC TECHNICAL GUIDELINES The following Plant Specific Technical Guidelines have been developed for the Browns Ferry Nuclear Plant:

Reactor Control Guideline Primary Containment Control Guideline Secondary Containment Control Guideline

- Radioactivity Release Control Guideline The purposes of the Reactor Control Guideline are to:

- Maintain adequate core cooling Shutdown the reactor ,

Cooldown the reactor to cold shutdown conditions-The Reactor Control Guideline accomplishes these purposes by controlling the three major reactor' parameters; reactor water level, reactor pressure, and reactor power.

The purpose of the Primary Containment Control Guideline are to:

- Maintain primary containment integrity

- Protect equipment inside the primary containment The Priaary Containment Control Guideline accomplishes these purposes by controlling suppression pool water level and water temperature, drywell average air temperature, and primary containment pressure.

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The purpoos of ths Secondcry Containmtnt Control Guideline tra to Protect equipment inside the secondary containment Limit radioactivity releases to the secondary containment Either maintain secondary containment integrity or limit radioactivity releases from the secondary containment The Secondary Containment Control Guideline accomplishes these purposes by controlling secondary containment temperatures, radiation levels, and water levels.

The purpose of the Radioactivity Release Control Guideline is to limit radioactivity release into areas outside the primary and secondary containments.

The Radioactivity Release Control Guideline accomplishes this purpose by controlling offsite radioactivity release rates.

These PSTGs are primarily based on revision 3 of the generic Emergency Procedure Guidelines (EPGs) developed by the BWR Owners Group. However, the attached PSTGs contain material from later ravisions of the EPGs as a result of:

1) Many enhancements / improvements made to the EPGs as a result of improved analytical methods, increased quantities of available data, and comments from various utilities concerning the EPGs.

2) Problems / concerns arising from E0P implementation at other BWRs.

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PSTG Development The BWR Owners Group EPGs were written to be generic in nature (i.e. they apply to all BWR Nuclear Steam Supply System (NSSS) designs 1 through 6 and all containment types Mark 1, 2, and 3). They address all major systems which may'be used to respond to an emergency condition or a condition which could degrade into an emergency. Our plant specific guidelines are developed from the Owners Group EPGs by performing the following actions:

- Evaluate steps frem the generic EPGs to determine applicability and desirability for use in our PSTGs. Since the EPGs are generic in nature, there are some steps that will not apply to Browns Ferry. These steps must either be deleted or replaced with the corresponding plant specific material. In some cases, our guidelines may deviate from the generic guidelines due to subsequent changes in analytical data, changes in ope' rating philosophy, etc.

- Evaluate cautions and notes from the generic EPGs to determine applicability and desirability for use (n our PSTGs. Some of the cautions from the generic EPGs have been placed in documents other than our PSTGs or deleted. We felt some of these conditions were better placed in other areas.

- Perform plant specific calculations to determine limits necessary for use in the PSTGs. These are included in Appendix C to our PSTGs.

- Assemble references for all plant specific information used in the PSTGs. This material is included in Appendix D to the PSTGs.

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C~ l D31ste all refereness to system 2 thtt do not apply to the Browns Ferry design. The design of Browns Ferry does not include all of the systems referenced in the generic EPGs. The l

EPGs are therefore applied to Browns Ferry by deleting '

references to systems which are not applicable or by substituting equivalent systems where appropriate. For example, Browns Ferry has no Isolation Condenser (IC), High Pressure Core Spray (HPCS), or Suppression Pool Makeup System (SPMS) and all statements referring to these systems have been deleted. In various locations throughout the guidelines where reference is made to the Low Pressure Core Spray (LPCS) system, this reference is changed to Core Spray (CS).

Incorporate plant specific limits, setpoints, and other applicable plant specific data. Brackets within the EPGs enclose plant unique procedures, setpoints, design limits, etc. Procedures within brackets indicate the source for the bracketed variable. These bracketed values are obtained from a variety of source documents including but not limited to, Technical Specifications, FSAR, Appendix 'C' calculations, plant drawingsi design documents, plant operating procedures, and vendor manuals. Additionally, the EPGs contain, in certain places, a general category of systems indicated by brackets, i.e. (other steam driven equipment], or a bracketed list of systems that could be used to carry out a particular action.

Using the guidance contained in the above listed reference documents, these lists are then also made plant specific.

- Evaluate plant specific instrumentation and control needs to determine if all tasks called out in the PSTGs can be performed. If not, determine what changes need to be made to ensure all required tasks can be performed.

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Tha PSTG3 vsra developtd by parsonnel poetessing the folicwing ekilla cnd with the following areas of expertise:

- Reactor engineering Plant operations..................SR0 Licensed or Certified BWR systems.......................SRO Licensed or Certified

- Operator training.................SR0 Licensed or Certified Control rooms design review.......SRO Licensed or Certified In addition to the above listed areas of expertise, the PSTGs (and changes thereto) require review by other site organizations leading up to PORC review and Plant Manager approval. Examples of these other organizations include QA, site procedures, RadCon, I & C, and Technical Support Services.

The following is a serial order of activities followed in developing the Browns Ferry PSTGs:

1) Evaluate steps from the generic EPGs to determine applicability and desireablity for use in the PSTGs.

2) Evaluate cautions and notes from the generic EPGs to determine applicability and desirability for use in the PSTGs.

3) Delete all references to systems that do not apply to the Browns Ferry design.

4) Incorporate plant specific limits, setpoints, and other applicable plant specific data.

5) Evaluate plant specific instrumentation and control needs to determine if all tasks called out in the PSTGs can be performed.

6) Perform in-house review of PSTGs (or changes thereto).

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7) Perform verification on PSTGs (or changes thereto).

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8) Hava all effseted secticns parform a technicc1 rsview of tha PSTGs.

9) PORG review and Plant Manager approve PSTGs.

There are four appendices to the Plant Specific Technical Guidelines. These appendices are not included as part of this submittal but are described below for information.

Appendix A provides a detailed discussion of the basis for each variable and curve used in the PSTGs where the basis is not evident from the text.

Appendix B provides a detailed discussion of the technical basis for each entry condition, caution, note, and step in the PSTGs.

Appendix C contains the reference calculations necessary to develop the tables, limits, and graphs in the PSTGs.

Appendix D contains a list of the source documents from which all of the plant

• specific limits, setpoints, etc. are obtained that are used in the PSTGs.

E0I DEVELOPMENT The E0Is are developed from the PSTGs using the following methodology:

1) The technical information contained in the PSTGs is translated into usable procedure steps in accordance with the E0I Writers Guide. The writers guide dictates the format to be used in development of the E0I steps and applies human factors principles during this stage of the procedure development.

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2) Amplifying information is added where nsceszary to assist the operators in more easily performing the steps. One of the objectives in writing the E0Is is to minimize the use of referencing as much as possible. Any place where additional information is required by the operators to perform the steps called out in the procedure, that Information is added to the procedure. The only exception to this is in the cases where the additional material is somewhat lengthy. There is no strict requirement as to when the additional material would be added to the procedure as opposed to being referenced, but a rule of thumb here is that if the additional material is more than one page in length, it would probably be referenced. This decision is left up to the writers discretion. In the cases where an abnormal system line-up is called out or a component is required to be used for a function other than that for which it was designed, the guidance required in order for the operators to perform these steps is added to the procedure.

Some examples of this are the use of systems as alternate injection sources or the use of systems or components for alternate depressurization of the reactor.

The instrumentation and controls incorporated into the E0Is were those specified in the PSTGs. A human factors evaluation was perfomred on the E0Is as part of the Detailed Control Room Design Review (DCRDR) to determine the acceptability of those instruments and controls. That evaluation was performed on the procedures, developed from the Rx Control Guideline and the Primary Containment Control Guideline of the PSTGs. Additional evaluation was later performed on the procedure developed from the Secondary Containment Control Guideline and the Radioactivity Release Control Guideline. These evaluations determined the instrumentation and controls (types, number, location, and characteristics) required in order to perform all of the tasks identified in the E0Is.

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There wera two sep2 rote aracc Eddreggsd during tha DCRDR with regard to instrumentation and control needs for E0Is; the task analysis, and the walkthroughs.

The task analysis was performed in accordance with the DCRDR Program Plan (see Detailed Control Room Design Review Action Plan, part A, "Task Analysis"). This task analysis was performed in two steps. The first step was to identify the instrumentation and control needs based on a task analysis of the E0Is including requirements for any special attributes.

The second step was to perform an analysis of existing control room instrumentation and controls that would be most appropriate for use in performing the E0I steps.

- Walkthroughs were performed using licensed Browns' Ferry operators in the control rooms. The task analysis results were reveiwed against the tesks the operators were performing to

, determine:

Whether or not control room instrumentation and controls satisfy the required attributes for task performance. .

The capacity of the operator to perform the task.

Task sequence, operator traffic patterns, communication requirements, and other factors that may impede operator task performance.

From these reviews, analysis, and walkthroughs, Human Engineering Concerns (HECs) were generated and evaluated. The end product of these evaluations is a list of Human Engineering Discrepancies (HEDs) which require resolution.

The documentation for these items is contained in the DCRDR Action Plan, section III, "CRDR Assessment Methodology", part B, "Findings and Recommendations." The documentation for the recent task analysis will be submitted as an addendum to the original DCRDR Program Plan.

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Operctieno is reIpsnoible for ths devalcpmInt tnd revisien of tha E0Is snd ths E0I Writers Guide. Technical Support Services is responsible for the maintenance of the PSTGs and their appendices and the Deviations Gross Reference Document (which contains the deviations between the generic Owners Group EPGs and the Browns Ferry PSTGs). Operations and Technical Support Services coordinate their efforts in order to develop or revise the E0Is.

Technical Support Services supplies the technical information and Operations ensures that the material is translated into procedural steps in accordance with the E0I Writers Guide.

The appropriate unit specific E0Is will be located in each units control room so that they are immediately accessible to operators while performing their control room duties.

The E0Is are uniquely identifiable and labeled to facilitate rapid identification and access to any procedure or any portion of a procedure. The current E0Is are kept in a five section binder that is unique to Browns Ferry and is easily distinguishable from all other procedures in the control room.

E0I changen will typically be required as a result of either: 1) changes to the geteric EPGs which need to be implemented at Browns Ferry, or 2) procedure change requests generated during training, ongoing E0I review, or any other site function affecting the E0Is. In either case, if the change requires a PSTG change, this change should be made first. The E0I change is then made in accordance with the revised PSTG. The following is a serial order of activities that would be followed in order to develop or revise an E0I:

NOTE: The formal review and approval processes for the changes to the PSTGs and the E0Is may be done in parallel.

- Incorporate the new technical information into the PSTGs and their appendices.

- Perform in-house review of PSTGs and their appendices.

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Cocrdinnte with Technical Suppsrt Sarvices to-obtain ths necessary technical information for inclusion into the E0Is.

Develop the E0I steps based on this technical information and in accordance with the guidance contained in the E0I Writers Guide. Add in any amplifying information necessary.

Perform in-house review of the upgraded E0Is.

Following the technical review (and incorporation of appropriate comments), verification and validation (V & V) will be performed.

Incorporate appropriate comments and resolutions from V & V and prepare final drafts of the PSTGs and the E0Is.

Process these changes in accordance with existing plant methodology governing procedure development and revision.

Including in this process are the following items:

1) Since these are safety related documents, a 50.59 evaluation is required,

2) Performance of an independent technical review and incorporation of applicable comments.

3) Performance ci a Quality At ance (QA) review and incorporation of applicable comments.

4) Plant Operations Review Committee (PORC) review and approval.

Train operators on the new or revised material.

Implement the new or revised material.

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E0I WRITERS GUIDE The E0I Writers Guide is used to translate the technical information contained in the PSTGs into usable procedures. This writers guide will ensure that the E0Is are readable, properly formatted, and incorporate appropriate human factors principles. It will also ensure that all E0Is are consistent in context and style. The writers guide will be used exclusively in developing and revising the E0Is.

The following general guidance is addressed in the Writers Guide:

- Organization; lists the various sections that are contained in each E0I and describes the three types of procedures contained in the E0Is (parameter control procedures, contingency procedures, and appendices)

- Format; describes the page headings to be used throughout the E0Is, describes the major procedure headings used in each section of the E0Is, outlines the proper format for caution and note statements, describes the numberind/ lettering scheme to be used for the E0Is, and outlines the format to be used for charts, tables, and diagrams Style; contains guidance concerning sentence structure, punctuation, vocabulary, abbreviations and acronyms, component identification, and use of logic terms

- Content; discusses the use of action statements including referencing and step sequencing, the purpose and centent of notes and cautions, and notes concerning charts, tables, and diagrams

- Typing instructions; describes the requirements for page margins, cpacing, etc.

The writers guide also contains attachments with lists of acceptable action verbs and acceptable abbreviations and acronyms.

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The Br wns Fstry Writers Guids will be controlled ca en approvsd plcnt procedure, Plant Manager Instruction (PMI)-12 7, Writers Guide for Emergency Operating Instructions. Since this procedure is considered safety related, it is required to tindergo (in addition to the technical reviews) a review by QA and approval by PORG.

This writers guide is based on the following source documents:

Emergency Operating Procedures Writing Guideline (INPO 82-017) developed by the Emergency Operating Procedures Implementation Assistance (EOPIA) Review Group and published by INPO

- Guidelines for the Preparation of Emergency Operating Procedures (NUREG-0899)

E0I VERIFICATION PROGRAM The E0I Verification Pro sram is the evaluation performed on the Browns Ferry E0Is and the Browns Ferry PSTGs in order to ensure that these documents are:

< - Technically accurate; that the information contained in the PSTGs and the E0Is is consistent with and accurately incorporates the techn? cal information contained in their source documents

- Written correctly; that the information in the E0Is is trasented in a manner that is consistent with the guidance contained in the E0I Writers Guide The verification of the PSTGs and the E0Is shall include, but not be limited to, the following items:

- Ensuring thct the PSTGs are consistent with the Emergency Procedure Guidelines (EPGs) and all deviations (and associated justifications) are documented Page 15 of 378 , , . . ,

- Ensuring thst-ths E0In era consistent with the PSTG3

- .JEnsuring that the plant specific limits and setpoints used in the PSTGs and in the E0Is are correct and have their reference sources documented in Appendix 'D' to the PSTGs

- Ensuring that the organization, format, and writing style used in the E0Is is consistent with the guidance outlined in the E0I' Writers Guide

- Ensuring that the references from one section of an E0I to another.

section or to another approved plant procedure are necessary and accurate The verification will be performed using personnel from the Technical Support Services section and will be associated with one or more of the following groups:

- Reactor Engineering Shift Technical Advisors

- Systems Engineering In order to ensure an independent verification, personnel performing the verification must not be the same people who developed or revised the PSTG or E0I being verified. -Verifiers should be selected based on their knowledge and understanding of plant operations and the PSTGs and E0Is.- Depending on the scope of verification, it may be necessary to utilize verifiers with expertise in other areas (such as human factors) to supplement the personnel described above.

'For revision two of the E0Is, the entire set of E0Is will be verified including verification of the PSTGs. For subsequent revision of the E0Is and/or PSIGs, verification will be handled in one of two ways.:

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1) For cajor reviciens, (i.e those involving tddition of n:w tschnicci material, those involving an intent change in the procedure, or those involving resequencing of steps or sections of the procedure), the steps in the E0Is and the PSTGs that were changed will be reverified. Alsc, an overall review of the entire E0I/PSTG will be done to ensure that the revision does not impair the intent of the procedure as a whole.

2) For minor revisions (i.e. those involving changes in nomenclature, administrative changes, etc.) verification will be left up to the discretion of the Operations Superintendent.

Verification of the newly developed PSTG material (Secondary Containment Control and Radioactivity Release Control) and corresponding E0I sections will be completo prior to training taking place on this material. For existing PSTG/E0I material, verification will be performed in parallel with ongoing E0I training.

Verification will be controlled by an approved plant procedure, PMI-12.8, Verificat4on of Emergency Operating Instructions. Since this procedure is . ,

considered safety related, it must receive (in addition to the technical review) QA review and must be approved by the PORC.

The verification program is based on the following source documents:

INPO 83-004, Emergency Operating Procedure Verification Guidelines NUREG-0899, Guidelines for the Preparation of Emergency Operating Procedures Verification Process The verifier begins by teviewing the source documents to ensure that they are complete, current, and applicable for the scope of verification.

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V:rific tien of ths PSTG3 Verification of the PSTGs will ensure that the PSTGs are technically accurate (i.e. the PSTGs properly incorporate the technical information in the EPGs).

The verifier shall review the PSTGs against the PSTG evaluation criteria contained in PMI-12.8.- The object here is to determine if each caution, note, or step in the PSTGs is acceptable with respect to the evaluation criteria. Any discrepancies found shall be documented on Verification Discrepancy Forms.

Verification of E0Is Verificaticn of the E0Is will ensure that the E0Is are technically accurate and written correctly (f.e. the E0Is properly incorporate the technical information from the PSTGs and present that information in a manner that is consistent with the guidance contained in the E0I Writers Guide).

The verifier shall review the E0Is against the E0I evaluation criteria contained in PMI-12.8. The verifier shall determine if the general organization and format of the E0Is is acceptable with respect to the evaluation criteria and d.termine if each caution, note, or step is acceptable with respect to the evaluation criteria. All discrepancies found shall be documented on the E0I Discrepancy Forms to ensure adequate resolution.

Resolution All discrepancies found during the verification shall be resolved.

Operations shall assign personnel tc prepare a resolution for each discrepancy. Once the tentative resolution has been prepared, the verifier shall review the resolution. The verifier must concur with each resolution. The verifier shall review the resolution to ensure that it completely resolves the discrepancy and does not introduce any new discrepancies.

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Operatieno will r; view and cppr ve each discrepincy cau prepricts  !

resolution. Operations will be responsible for ensuring that each resolution is incorporated into the E0I or PSTG. Evaluation by Operations is required to determine if further training and/or validation is required as a result of the discrepancy resolution.

Verification Doccmentation Each verification shall be documented on a Verification Control Sheet. This form serves as a cover sheet and provides information on the scope and status of the verification. One of these forms is required for each document being verified. This control sheet documents the title, number, and revision of the document to be verified, the scope of the verification, the source documents to be used for the verification, and tracks the verification process from beginning to end. This control sheet also lists each discre;ancy discovered during the verification procens and tracks these discrepancies until all are closed. The verification process is not closed until all discrepancies and their corresponding resolutions have been reviewed and the control sheet signed off by the Operations Superintendent.

There are Verification Evaluation Sheets for both the PSTGs and the E0Is.

These sheets are used by the verifier to check each step, caution, or note of the E0Is and the PSTGs against the evaluation criteria to determine its acceptability. If the a. valuation criteria are met for a particular item, that item is checked acceptable. If all evaluation criteria are not met, the item in question is unacceptable and a discrepancy sneet is generated to document the identified prob 1;m.

The Discrepancy Sheet is used to document all identified discrepancies and track them until closure. These sheets describe the nature of the discrepancy and the resolution recommended for the discrepancy. These discrepancy sheets are also used to identify whether or not further training and/or validation is required because of the resolution to this discrepancy.

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-E0I VALIDATION PROGRAM The E0I Validction Program is the evaluation performed on the Browns Fer ry FOIs in order to ensure that:

- The E0Is are usable; they can be understood and followed without confusion, delays, errors,-etc.

- There is e correspondence between the procedures and the control-room / plant hardware, i.e. controls / indications / equipment that are referenced, are available, use the same units of meaaurement, use the same designation, and operate as specified in the procedures

- The language and level of informstion presented in the 20Is are compatible with the minimum numbor, qualifications, training, and experience of the operating staff There is a high level of assurance ths' 'he procedures will work, i.e. the procedures guide the operators in mitigating transients and accidents The validation of the E0Is shall include, but is aot limited to, the following items:

L 4 - Ensuring that the level of detail in the E0Is is sufficient for the j' operators to effectively carry out the required actions Ensuring tha'c the procedures are understandable from the standpoint of organization, readability, and completeness i - Ensuring that the operators could obtain all required information

from designated plant instrumentation without difficulty 1

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_L En uring that ths controls es11cd out in the E0Is cre etaily identified-and can be manipulated as specified in the procedures Ensuring that the shift personnel can effectively use the E0Is The validation will be performed using personnel from the following groups:

-- Operations

- Technical Support Services

- Training Evaluators should be designated based on their knowledge and un.derstanding of plant operations, E0Is and other procedures, training, and the validation methods. -

Depending on the scope of the validation, it may be necessary to utilize validators with expertise in other areas (such as human factors) to supplement the personnel described above. ,

.For revision two of the E0Is, the entire set of E0Is will be validated. For subsequent revisions of the E0Is, validation will be handled in one of two ways:

1) For major revisions, (i.e. those involving addition of new technical material, those involving an intent change in the procedure, or those involving resequencing of steps or sections of the procedure) the steps that were changed in the E0Is will be revalidated

2) For minor revisions (i.e. those involving changes in nomenclature, administrative changes, etc.) revalidation will be left up to the discretion of the Operations Superintendent Page 21 of 378 , , , , ,

'Vclidaticn of the newly developed E0I material (See ndcry Containm:nt C:ntrol and Radioactivity Release Control) will be complete prior to training taking place on this material. For existing E0I material, validation will be performed in parallel with ongoing E0I training.

The only significant differences in the E0Is occur in the area of the E0I appendices. Those portions of the procedure cannot be validated on the simulator and must be validated by means of table-top discussions and walkthroughs. When changes are made to the appendices, these changes are discuar sd first so that the operators gain an understanding of the differences, then walkthroughs are performed in each unit to complete validate on these changes.

In the future, if changes are made that can be validated on the simulator, these changes will be handled by means of discussions before the simulator part of the validation to ensure that the difference does not present a problem between operation of the units.

Validation will be controlled by an approved plant procedure, PMI-12.9, Validation of Emergency Operating Instructions. Since this procedure is considered safety related, it must receive (in addition to the required technical review) a QA review and must be approved by PORC.

The validation program is based on the following source documents:

INPO 83-006, Emergency Operating Procedures Validation Guideline NUREG-0899, Guidelines for the Preparation of Emergency Operating Procedures Page 22 of 378 , ,, ,

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Validaticn Process Selection of validation method The Operations Superintendent shall be responsible for selecting the appropriate validation method based on the nature of the change or revision. There are three methods of E0I validation:

- Table-top

- Walkthrough

- Simulator The simulator method of validation is preferred and should be used where practical because it more accurately demonstrates operator response to a specific scenario. The simulator method is also more effective at pointing out discrepancies between the procedures and the hardware and between the procedures and the operators executing them.

If the simulator method of validation is not practical, the walkthrough method of validation should be used, This method is atore effective than a table-top discussion at ensuring the necessary 3evel of detail is in the procedures and that the procedures and that the procedures / hardware / personnel are compatible.

If the procedures to be validated are such that the simulator and walkthrough methods cannot be used effectively, then 6 table-top discussion method of validation will be used. If the table-top method of validation is used, it shall be accompanied by either a control roon walkthrough or use of plant mock-ups or plant drawings to verify consistency bete'en tne procedures and the control room / plant hardware.

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i i Scenario selecticn The evaluation team shall be responsible for selecting scenarios to guide the operators through E0Is steps so that the evaluation criteria vill be addressed. The scenario will provide a structured plan of parameter and plant symptom changes which describe evtuts designed to exercise the E0I (or portions thereof).

Scenarios are developed based on the following criteria:

Ensure that all new or revised steps are checked during the performance of the validation Utilize both single and multiple failures, where practical litilize concurrent and sequential failures, where practical For sections of the procedure that cannot be validated on the simulator because of simulator limitat. ions, use control room or simulator walkthroughs to validate.

Scenarios will vary in length and complexity depending on the validation method used. Scenarios for the table-top or walkthrough methods should be bore detailed than for the simulator method to provide the perator with a precise definition of the plant status at r.ay gi'ren time.

Browns Ferry requalification training program simulator scenarios may be used or modified as necessary. The evaluation team will review already developed scenarios and select those appropriate for the validation method and the E0I being evaluated.

Validation scenarios should be run using the minimum control room staff si'te required by the plant Technical Specification to ensure that all activities and steps called out in the E0Is can be perforced as specified.

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Ressrdless of tho validstien cathsd u2sd, thz following generci ssquencs of steps will be followed in ,e3 forming the validation:

- Schedule for the use of operators to participate in the validation.

The operators selected should be representative of the training level expected of all operators l

- Arrange for the needed resources to support the validation (i.e.

copies of E0Is and related procedures, related technical documentation, etc.)

- Review the purpose and objective of the validation with the operators involved

- Brief the operators on how the validation will be performed

- Review the scenarios and any underlying assumptions with the operators

- Familiarize the operators with the new E0I (or E0I section) or the char s made to the existing E0Is. Identify the instruction steps which the operator could follow in managing the event and describe expected operator responses. ,

Evaluate simulator characteristics (if the sivalator method of validation is being used) different from the actual control room for impact on the validation.

- During the performance of the validation, the evaluators will assess the E0Is by noting any performance deviations. PMI-12.9 contains checklists that will be used it the assessment of the EDIs.

- Debrief the operators following the validation. Have the operators present any problem 7 which they identified during that phase of the validation. Discuss any performance deviation noted during that portion of the validation. Generate discrepancy sheets for all identified discrepancies.

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R021utien All discrepancies identified during validation must be resolved. The evaluation team is responsible for developing resolutions for identified discrepancies. Depending on the nature of the discrepancy, the resolution may require changes to the procedures, additional training, or, in some cases, no change. Where no change is recommended as the resolution, a justification not to change must be provided.

The evaluators should solicit operator input during the debriefing sessions regarding potential resolutions to discrepanttes. The evaluators will ensure that the developed resolution completely resolves the discrepancy without introducing any new discrepancies.

The Operations Superintendent will review and approve each discrepancy and resolutions. Operetions will te r-sponsible for ensuring each resolution is dispositioned as required, i.e. revision of the E0Is, training program changes, etc.

Validation documentation Each validation shall be documented on a Validation Control Sheet. This form serves a cover sheet and provides information on the ccope and status of the validation. This control sheet documents the tit 7e, number, and revision of the document to be validated, the scope of the validation, the source documents to be used for the validation, and tracks the validation process from beginning to end. This control sheet also lists each discrepancy discovered during the validation process and tracks these discrepancies until they are closed. The validation process is not closed until all discrepancies and their corresponding resolutions have been reviewed and the control sheet signed off by the Operations Superintendent.

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E0I Secntric She:ts cre includ:d.in the packegs of documentatien for the validation. These sheets describe the scenarios that are used for the validation including the purpose / objective of the scenario, a description of the scenario, the initial conditions existing at the beginning of the scenario, a list of evaluators and operators involved, and an outline of the action progression that is expected as the scenario is carried out. ,

l The Discrepancy Sheet is used to document all identified discrepancies and track them until closure. These sheets describe the nature of the discreparcy and the resolution recommended for the discrepancy. As with the discrepancy sheets used for verification, these sheets have to be signed off by the Operations Superintendent prior to being considered closed.

E0I TRAINING PROGRAM -

The Emergency Oparating Instruction (E0I) training program is designed such that, at the completion of training. tha .tainees will:

- Understand the history of and the philosphy behind the change from event-based to symptom-based Emergency Operating Procedures.

- Understand the structure and technical bases of the E0Is (included in here are bases for the curves, limits, cautions, notes, and steps in the Plant Specific Technical Guidelines and the E0Is).

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- Have obtained a working knowledge of the E0Is.

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- Be able to use the E0Is under adverse conditions in the simulator.

E0I training has been ongoing since initial implementation of the E0Is. This training consists of classroom training, simulator training, and control room / plant walkthrough. In addition, some of the non-licensed Assistant Unit Operators (AU0s) are now receiving some additional basic training courses (such as Basic Electrical Training) that will allow them to assume more responsibility in performing actions called out in the E0Is. The following is a brief discussion of each of the types of training related to E0Is.

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Classroom traininn

• Licersed personnel Both initial license training groups and requal training groups receive classroom instruction relative to E0Is. The instruction time for this training varies from 24-4C hours. Over the course of this training period, the following topics are discussad:

A discussion of the philosophy behind the change-over from event-based procedures to function-based or synptom-based procedures

- A history of the events that followed the accident at the Three Mile Island Nuclear Plant and the evolution of the Emergency Procedure Guidelines The operators are given an overview of the E0Is where they discuss the relationship between the various sections that make up the E0Is and the general flow of the procedures Each caution is discussed with respect to its use and applicability.

The operators are taught the basis of each of the curves in the E0Is and how to read and interpret the information contained in the curves.

The instructors then step through the antire E01 discussing the basis of each of the steps in the procedure.

• Non-licensed personnel The AUOs also receive classroom training on E0Is. This training consists of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> classroom training covering the following topics:

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Ths AUOn cre first givtn cn overvisw of the E0Io so th;t thsy will hzv3 o basic underattnding of ths alcmints contcined in the procedures. This does not contain a detailed discussion of the basis for the steps but is more of a familiarization with the procedure.

The majority of the time is spent discussing the appendices and the actions contained within them. The AUOs will be primarily involved in performing the manual valve line-ups called out in the E0I appendices.

Simulator Traininz

• Licensed personnel only Simulator training for the licensed personnel consists of 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of training dedicated strictly to the E0Is and an additional 20 to 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> training that involves the use of the E0Is, but is not limited just to E0Is.

The 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> dedicated to E0Is involved running scenarios that are designed to get the operator'into the E0Is immediately after the initiating event. During the execution of these scenarios, the operators will use the E0Is almost exclusively. The scenarios that are used contain single and multiple failures along with concurrent and sequential failures ,

in order to give as many looks to the operators as possible.

During the additional 20 to 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> training that involves the use of the E0Is, more comprehensive scenarios are utilized to exercise other procedures in addition to the E0Is. These scenarios typically start with less severe initiating events and progress until the E0Is are entered. In this manner, many other types of procedures are used during the course of the acenario. A scenario of this type might typically start with an event requiring entry into an Annunciator Response Procedure, degrade somewhat until an Abnormal Procedure might be required, and eventually degrade until entry into the E0Is is required.

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Examples of ccencrica th t night ba ursd for simulator training ere co foll'ows :

E0I Traininz oniv: The initiating event is a' stuck open Safety Relief Valve (SRV) from 100% power that cauces the temperature of the suppression pool to rise. A manual scram is attempted, but fails.

Water level is lowered in order to reduce reactor power. Standby Liquid Control (SLC) is injected. Manual rod insertion stepu are carried out per the reactor power control sect?on. Rods insert when the Reactor Protection System (RPS) fuses are palled. Boron injection is terminated and reactor water level is returned to normal.

Comorehensive training includinz E0I use: The plant is initially at 100% power. Reactor power is being reduced to 70% for rod pattern edj us t= site . During the power reduct' ion, the 'A' Reactor Recire Pump trips. Once this pump is recovered, 4KV Shutdown Board 'A' is lost due to a fault. This failure indirectly causes loss of all Reactor Feedwater Pumps. The reactor fails to completely scram once the appropriate lov level is reached. Operators enter the E0Is to control water level and get the reactor completely shutdown. Water level is restored using available systems and the rods are completely inserted once the RPS fuses are pulled. The operators would then exit the E0Is and enter the scram procedure.

During the simulator sessions, the instructors will concentrate on the following items: ,

- Operatcr responsibilities Flow of information

- Interaction between operators in the control room Page 30 of 378 . , , ,

Th2 emphecio in the siculctor ic on team training (i.o. coordinction between the members of the group). During the training sessions, each crew is trained to perform all of the actions called out in the E0Is.

Operators are rotated through each position in the group. In this way, each operator is trained to read the E0Is and direct actions required for each position on the operating crew.

For the actions that are taken outside the control room, there are two ways that *hese can be handled. The Shif t Operations Supervisor (SOS) can direct the actions from the control room or he can give a list of the steps (or the entire appendix) to the Assistant Shift Operations Supervisor (ASOS) and have him perform these actions locally and report to the SOS when these actions are complete.

The choice between these two methods is dictated by the availability of personnel and the number and complexity of the steps to be executed.

In some cases, limitations on the capabilities of the simulator may preclude being able to perform all of the required actions on the simulator. In these cases, the steps that cannot be performed on the simulator will be discussed and walked through by the crew and the instructor.

Walkthrough Training

• Licensed personnel The licensed personnel receive approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> walkthreugh training in the control room and in the plant. These walkthroughs focus on manual manipulations required by the E0Is a) i located in the E0I appendices.

Some examples of these manual manipulations are: installing jumpers, lifting leads, installing contact boots, etc. During these walkthroughs, the instructors take along the actual tools and other hardware that would be used to execute the steps called out of the E01a. In this way the operators learn the location of all of the panels and switchgear where the manual actions are performed and they also handle the tools and hardware required to perform these actions and ensure its suitability.

Page 31 of 378

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.F In cdditicn to the hands-en training reesivsd by virtus of th;ce physicci valkdowns, the instructors also discuss in the classroom, the system line-ups and effect on system operation specific appendices will have (i.e. what function of a logic train is being jumpered by the installation of a jumper). Currently, the ASOSs are the people primarily rasponsible for carrying out these actions performed outside of the control room.

These walkthroughs are primarily geared toward them, however all licensed personnel receive this training.

• Non-licensed personnel The walkthrough training for the non-licensed people consists of approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of in-plant walkthroughs. During these walkthroughs the emphasis is placed on performing the manual valve line-ups called out in the E0I appendices. The AUOs are the personnel primarily responsible for carrying out these manual valve line-ups under the direction of the ASOSs. During these walkthroughs, the AUOs are shown the location of all equipment required to be operated in the E0I appendices. The instructors also utilize marked-up copies of plant drawings to illustrate to the AUOs the purpose of the. steps they are performing.

The AU0s are currently being sent through additional training courses to enhance their ability to perform these actions called out in the E0Is.

For example, some of_the AUOs have been sent through the Basis Electrical Training course among others and are now being utilized to perform some of the appendix actions such as installing and removing jumpers and lifting leads that had previously been done only by the ASOSs.

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Unit Differences Differences between the three units are handled in a number of different ways. There is a comprehensive effort to ensure the operators are aware of existing differences among the units. The following discussions outline the mechanisms in place for handling differences between the units:

For hot license training, there is a separate lesson plan used for instructing the students in the differences that exist between the units.

With respect to unit differences, the written examinations are used to verify that the oprators are aware of differences among the units.

There are questions that test the operators knowledge of different systems configurations, differences in component power supp' lies, different logic schemes, etc., as appropriate.

- For plant modifications that require training, impact forms are sent to the training department notifying them of the need to develon additional training material. If the modification involves a change that will create -a difference between the units, this is specified in the lesson plans affected by the modification. These changes are then brought to the attention of the operators during classroom training.

These changes are also reinforced during simulator training which takes place after the corresponding classroom training sessions are complete. The differences are discussed during the debriefing sessions which are held following the simulator runs.

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, TENNESSEE VALLEY AUTHORITY BROWNS' FERRY NUCLEAR-PLANT EMERGENCY OPERATING INSTRUCTION PLANT SPECIFIC TECHNICAL GUIDELINES 3-i

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TABLE OF CONTENTS SECTION PAGE Preface......................................................... 37 Introduction.................................................... 38 Operator Cautions............................................... 45 Rx Control Guideline............................................ 48 RC/L....................................................... 49 RC/P....................................................... 52 RC/Q....................................................... 55 Primary Containment Control Guideline........................... 58 SP/T....................................................... 59 DW/7,...................................................... 60 PC/P....................................................... 61 SP/L....................................................... 64 S econda ry Containment Control Guideline . . . . . . . . . . . . . . . . . . . . . . . . . 67 SC/T....................................................... 69 SC/R....................................................... 70 SC/L....................................................... 71 Radioactivity Release Control Guideline......................... 75 Contingencies 1 - Al t e rna t e Level Cont rol . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 6 2 - Emergency Rx Depressurization.......................... 81 3 - Steam Cooling.......................................... 83 Page 35 of 378

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TABLE OF CONTENTS SECTION PAGE 4 - Rx Flooding............................................ 84 Level / Power Control.................................... 89 7 - Core Cooling Without Level Restoration................. 94 TABLES I -

Abbreviations / Definitions.................................. 41 II - Operating Values of Secondary Containment Parameters....... 72 FIGURES A'- Rx Saturation Temperature................................... 95 B - RHR NPSH Limits............................................. 96 C - Drywell Spray Initiation Limit.............................. 97 D - Pressure Suppression Pressure Limit......................... 98 E - Heat Capacity Level Limit................................... 99 F - Heat Capacity Temperature Limit............................ 100 G - Suppression Pool Load Limit................................ 101 H - CS NPSH Limits............................................. 102 Page 36 of 378 4

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PREFACE These Plant Specific Technical Guidelines were developed from the Boiling Water Reactor Owners Group generic Emergency Procedure Guidelines, Revision 3, dated December 8, 1982. However, some changes / enhancements have been incorporated as a result of subsequent changes to the Emergency Procedure Guidelines brought about by:

1) Implementation concerns from various utilities

2) Improvements in the calculational procedures used to determine the limits contained in the Emergency Procedure Guidelines Although similar, the format of the Plant Specific Technical Guidelines is not intended-to reflect the format of the Emergency Operating Instructions (E0Is) developed from these guidelines. Format of the E0Is will follow the instructions of the E0I Writers Guide.

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INTRODUCTION 4

- Based on the BWR' system design, the following. Plant Specific Technical i Guidelines have been developed

- Rx Control Guideline

- Primary Containment Control Guideline-

--- Secondary Containment Control Guideline

- Radioactivity Release Control Guideline  :

- Contingencies

• The Rx Control Guideline contains instructions to enable the operator to maintain adequate core cooling, shut down the reactor, and cool down the Rx to-cold shutdown conditions. This guideline is entered whenever low Rx watar level, high Rx pressure, high drywe11' pressure, a condition which requires MSIV isolation has occurred, or whenever a condition which requires a reactor scram exists and reactor power is above the APRM downscale trip or'cannot be determined.

The Primary Containment Control Guideline contains instructions to enable the l' operator to maintain primary containment integrity and protect equipment inside the primary containment. This guideline is entered whenever suppression pool temperature, drywell temperature, drywell pressure, or suppression pool water level is above its high operating limit or suppression pool water level is below its low operating limit.

The Secondary Containment Control Guideline contains instructions to enable  ;

the operater to protect equipment inside the secondary containment, limit radioactivity release to the secondary containment, and either maintain

secondary containment integrity or limit radioactivity release from the ,

secondary containment. This guideline is entered whenever a secondary i containment temperature, radiation' level, or water level is above its maximum normal operating value or secondary containment differential pressure reaches j zero.

r i The Radioactivity Release Control Guideline contains instructions to enable the operator to limit radioactivity release into areas outside the primary and secondary containments. This guideline is entered whenever offsite radioactivity release rate is above that which requires an Alert.

• Technically, these are not considered guidelines themselves but rather should be viewed as supplements to the above listed guidelines.

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Tbc C:ntingenciss contcin in:tructions th t are used to provide optrctor l guidance during severely degraded plant conditions. They are supplements to the four major guidelines and are used in situations where plant conditions have degraded to such,a level that the guidance contained in the four major guidelines is no longer sufficient to ensure maintenance of the applicable critical safety functions. These critical safety functions are as follows:

- Containment integrity

- Reactivity control Heat removal

- Reactor coolant inventory control The following is a brief description of the purpose of each contingency:

Contingency 1 Alternate Level Control: Contains instructions to enable the operator to restore Rx water level to above TAF.

Contingency 2 Emergency Rx Depressurization: Contains instructions to enable the operator to effect a rapid Rx depressurization.

Contingency 3 Steam Cooling: Contains instructions to enable the operator to maintain adequate core cooling while attempting to establish a method of injecting water into the vessel.

Contingency 4 Rx Flooding: Contains instructions to enable the operator to assure the core is adequately cooled in situations where level indication is lost.

Contingency 5 Level / Power Control: Contains instructions to enable the operator to maintain adequate core cooling (level control) during ATWS conditions and to minimize suppression pool heatup during boron injection (if required) in the hope of avoiding emergency depressurization.

Contingency 7 Core Cooling Without Level Restoration: Contains instructions to enable the operator to provide a means of cooling the core at low pressure if water level cannot be maintained above TAF.

The contingencies do not have specific entry conditions like the four guidelines but are entered as directed from various points in the guidelines or other contingencies.

Setpoints, design limits, and components used in these guidelines are specific to Browns Ferry Nuclear Plant. Parentheses ( ) following these plant specific variables enclose the source for these variables .

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At variang_p?ints thrcughsut these guid211 nee, ccuticns cra n tid by tha symbol l# l. The number within the box refers to a numbered "Caution" contained in the Operator Cautions section. These "Cautions" are brief and succinct red flags for the operator.

Where the basis for the "Caution" or step is not completely evident from the text, a full discussion of the basis is contained in Appendix B to these Plant Specific Technical Guidelines (PSTGs). Other system details which pertain to the guidelines are also included in this appendix.

The PSTGs are developed from the generic Emergent.? Procedure Guidelines by deleting statements which are not applicable or by substituting equivalent systems where appropriate and by substituting the BFN specific setpoints, design limits, pump shutoff pressures, action limits, etc., where appropriate.

At various points within these guidelines, limits are specified beyond which certain actions are required. While conservative, these limits are derived from engineering analyses utilizing best-estimate (as opposed to licensing) models. Consequently, these limits are not as conservative as the limits specified in a plant's Technical Specifications. This is not to imply that operation beyond the Technical Specifications is recommended in an emergency.

Rather, such operation may be required under certain degraded conditions in order to safely mitigate the consequences of those degraded conditions. This guidance is in accordance with that specified in 10CFR50.54 (x). The limits specified in the guidelines establish the boundaries within which continued safe operation of the plant can be assured. Therefore, conformance with the guidelines does riot ensure strict conformance with a plant's Technical Specifications or other licensing bases.

The entry conditions for these guidelines are symptomatic of both emergencies and events which may degrade into emergencies. The guidelines specify actions appropriate for both. Therefore, entry into procedures developed from these guidelines is not conclusive that an emergency has occurred.

The curves, caut\ons, and steps of the PSTGs apply to all three BFN units unless specifically noted otherwise.

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TABLE 1 ABBREVIATIONS / DEFINITIONS WORD /ASBREVIATION MEANING / APPLICATION ADS Automatic Depressurization System Alternate Injection Subsystem Any of: Condensate Transfer system, HPCI (using auxiliary boiler-steam), PSC head tank pumps, RCIC (using auxiliary boiler steam), RHR crosatie to other units, RHR drain pumps, SLC, Standby Coolant APRM Average Power Range Monitor AUTO Automatic BWR Boiling Water Reactor F

G Contingency C1 Curies cont continued CRD Control Rod Drive 1

CS Core Spray CST Condensate Storage Tank des degrees DW/T Drywell Temperature Control ECCS Emergency Core Cooling System El Elevation E0I Emergency Operating Instruction F Fahrenheit ft foot or feet GOI General Operating Instruction GPM gallons per minute Page 41 of 378 e

TABLE 1 ABBREVIATIONS /DEFIN!TIONS WORD / ABBREVIATION MEANING / APPLICATION HCU Hydraulic Control Unit HPCI High Pressure Coolant Injection hr hour HVAC Heating, Ventilation, and Air Conditioning in. inch or inches

-Injection Subsystem Any of: Condensate, LPCI, or CS LCO Limiting Condition for Operation LI- Level Indicator LPCI Low Pressure Coolant Injection MAX Maximum min minute mr millirem MSIV Main Steamline Isolation Valv,e NE Northeast NPSH Net Positive Suction Head NW Northwest PC'S Primary Containment Isolation System PC/P Primary Containment Pressure Control PCV Pressure Control Valve PI Pressure Indicator Primary System Main Steam, HPCI, RCIC, Core Spray, RHR, CRD, Feedwater, RWCU, SLC, TIP are the designated primary systems.

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TABLE 2 OPERATING VALUES OF SECONDARY CONTAINMENT PARAMETERS MAX NORMAL MAX SAFE SECONDARY CONTAINMENT PARAMETER OPERATING- OPERATING VALUE VALUE AREA TEMPERATURE DEGREES T DEGREES F ,

HPCI room, El. 519- 175 290 NW corner room, El. 519 175 295 NE corner room, El. 519 150 180 SW corner room, El. 519 160 185 SE corner room, El. 519 160 265 Torus area, El. 519 (west) 175 280 Torus area, El. 519 (east) 160 280 Main Steam Vault, El. 565 160 300 Drywell Access, El. 565 160 205 General area, El. 593 160 205 ,

RWCU Pump room 2A, El. 593 120 220 RWCU Pump room 2B, El. 593 120 220

'RWCU Heat Exchanger room, El. 593 *120 215 Gene'ral area, El. 621 160 215 b

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TABLE 2 OPERATING VALUES OF SECONDARY CONTAINMENT PARAMETERS MAX NORMAL MAX SAFE SECONDARY CONTAINMENT PARAMETER OPERATING OPERATING VALUE VALUE t

VENTILATION EXHAUST RADIATION LEVEL MR/HR Reactor Zone 72 N/A Refuel Zone 67 N/A AREA RADIATION LEVEL MR/HR MR/HR HPCI room, El. 519 (HPCI in standby) 10 1000 HPCI room, El. 519 (HPCI running) 100 1000

'NW corner room, El. 519 10 1000 NE corner room, El. 519 10 1000 SW corner room, El. 519 80 -1000

,9E corner room, El. 519 80 1000 Torus area, El. 519 30 1000 ,

CRD-HCU area west, El. 565 100 1000 CRD-HCU area east, El. 565 100 1000

• TIP room, El. 565 (TIPS shielded) 1000 3000 TIP room, El. 565 (TIPS unshielded) 10,000 100,000 TIP drive, El. 565 10 1000 RWCU area north, El. 593 10 1000 RWCU area south, El. 593 10 1000 RWCU area, El. 621 10 1000 South side, El. 639 10 1000 Fuel Storage Pool Area, El. 664 10 1000 Service Floor Area, El. 664 10 1000 New Fuel Storage, El. 664 10 1000 t

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TABLE 2 OPERATING VALUES OF SECONDARY CONTAINMENT PARAMETERS MAX NORMAL MAX SAFE SECONDARY CONTAINMENT PARAMETER OPERATING OPERATING VALUE VALUE FLOOR DRAIN SUMP WATER LEVEL INCHES Sump 2A (SW corner) 66 N/A Sump 2B (SE corner) 66 N/A AREA WATER LEVdL INCHES INCHES NW corner room, El. 519 2 22 NE corner room, El. 519 2 '

21 SW corner room, El. 519 2 21 SE corner room, El. 519 2 21 HPCI room, EL. 519 2 20 Torus area, El. 519 ,2 22 6

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i RANI 0 ACTIVITY RELEASE CONTROL Cf7DELINE PURPOSE The purpose of this guideline is to limit radioactivity release into areas outside the primary and secondary containments.

ENTRY CONDIIl2H1 The entry condition for this guideline ist.

- Offsite radioactivity release rate above 140 Ci/sec (release rate which requires an Alert).

OPERATOR ACTIONS If while executing steps RR-1 and RR-2 turbine building ventilation is shutdown, restart turbine building ventilation.

RR-1 Isolate all primary systems that are discharging into areas outside the primary and secondary containments except systems required to assure adequate core cooling or shut down the Rx.

RR-2 When any of the following conditions exist:

Offsite radioactivity release rate approaches or exceeds 20,000 Ci/sec, OR Whole body dose at or b'eyond site boundary is at or above 1000 mr/hr, OR Thyroid dose at or beyond site boundary is at or above 5000 mr/hr, OR Activity at or beyond site boundary is at or above 1.46 x 10-6 microcuries/ cubic centimeter (uci/cc) for I-131 Equivalent but only if a primary system is discharging into an area outside the primary and secondary containments, EMERGENCY RX DEPRESSURIZATION IS REQUIRED; enter the procedure developed from the Rx Control Guideline at step RC/L, RC/Q, and C2 and execute it concurrently with the procedure developed from this guideline.

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CONTINGENCY # 1 ALTERNATE LEVEL CONTROL If while executing steps Cl-1 through Cl-8:

- Any control rod is not inserted to or beyond position 02 (Maximum Suberitical Banked Withdrawal Position), enter the procedure developed from CONTINGENCY 5..

- Rx water level cannot be determined, enter the procedure developed from CONTINGENCY 2.

Cl-1 Line up for injcetion, start pumps, and irrespective of ramp NPSH limits, increase injection flow to the meximum with two or more of the following injection subsystems:

- Condensate

- RHR , e) System I, placing the applicable RHRSW pump (s) in servic soon as possible

- RHR (LPCI mode) System II, placing the applicable RHRSW pump (s) in service as soun as possible

- CS System I

- CS System II Cl-2 If less than two of the injection subsystems can be lined up, commence lining up as many of the fol]owing alternate injection subsystems as poss!.ble :

Condensate transfer pur to RHR and CS 0 to 100 psig. O t. 1000 gpm

- SLC (test tank) aughsnted by demineralized water head tank 0 to 1400 psig,-23 gpm test tank capacity - 210 gallons demineralized water tank capacity - 30,000 gallons makeup available at 23 gpm SLC (F.';on tank)

O to 1400 psig, 50 gpm storage tank capacity - 4500 gallons RHR crosstie to other units 0 to 310 psig, O to 5000 gpm Page 76 of 378 , ,

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- Stcndby coolant 0 to 160 psig, O to.3500 gpm

- RHR drain pumps 0 to 40 psig, O to 600 spm FSC head tank pumpa 0 to 40 psig, O to 80 gpm

- RCIC (using at:t. hoiler tream) aux boiler steam pressure O to 250 psig i Rx pressure O to 350 psig, 600 gpm

- HPCI (using aux. boiler steam)

, aux. boiler steam pressure 0 to 250 psig Rx pressure O to 350 psig, 5000 gpm If while executing steps Cl-4 through Cl-8:

- Thn Rx water level trend reverses or Rx pressure changes region, return to step Cl-3.

Cl-3 Monitor Rx pressure and Rx water level. Continue in this guidelins at the step indicated by logic diagram Cl-3.

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Cl-3 LOGIC DIAGRAt1 STEP C1-3 7

Rx YES to

> 320 s psig V 7

'rEE to Rx

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r Rx Rx YES to YES 3 l -- level l

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V V V V V 7 C14 C17 C15 C17 C16 C18 Page 78 of 378 " --

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TABLE 1 ABBREVIATIONS / DEFINITIONS WORD / ABBREVIATION MEANING / APPLICATION PS Pressure Switch PSC Pressure Suppression Chamber psig pounds per squate inch gauge PSTG Plant Specific Technical Guideline RCIC Reactor Core Isolation Cooling RC/L Ex Level Control RC/P Rx Pressure Control RC/Q Rx Power Control RFPT Reactor Feed Pump Turbine RHR Residual Heat Removal RHRSW Residual Heat Removal Service Water rpA ,

revolutions per minute RPS Reactor Protection System RdCS Rod Sequence Control System R'.fCU Reactor Water Cleanup RWM Rod Worth Minimizer Rx Reactor SC/L Secondary Containment Level Control SC/R Secondary Containment Radiation Control SC/T Secondary Containment Temperature Control SDV Scram Discharge Volume SE Southeast Page 43 of 378 . , , _

.i TABLE 1

_ ABBREVIATIONS / DEFINITIONS WORD / ABBREVIATION MEANING / APPLICATION

.SGTS Standby Gas Treatment System SJAE Steam Jet Air Ejector SLC Standby Liquid Control SP/L Suppression Pool Water Level Control SP/T Suppression Pool Temperature Coi.;rol SRV. Safety / Relief Valve

- SW Southwest TI Temperature Indicator TIP Traversing Incore Probe TR Temperature Recorder e

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OPERATOR CAUTIONS This section lists Cautions which are applicable at one or more specific

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. points within these guidelines. Where a Caution is app 31 cable, it is identified with the symbol

1. n and located adjacent to the step to which it applies.

CAUTION #1 Use Rx water level instruments to determine Rx water letal only when all of the following conditions are satisfied:

1. The temperatures near the instrument reference leg vertical runs are below the Rx Saturation Temperature (See Figure A).

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2. For each of the instruments in the following table, the temperatures near the instrument reference les vertical runs are below the Maximum Run Temperature or the instrument reads above the minimum indicated level.

Minimum Maximum Temperature Indicated Run Instrument Point Level Temperature Post Accident Flooding Range (-100 to +200 in.)

LI-3-52 TI-80-34-6 -100 300 LI-3-62 Average of TI-80-34-7 & 8

• Emergency Systems Range (-155 to + 60 in.)

LI-3-46A(units 1,3) TI-80-34-6 -155 in. 180 deg F LI-3-58A(unit 2) *

-150 in. 220 deg F LI-3-46B(units 1,3) Average of 140 in. 300 deg F TI-80 34-7 & 8 LI-3-58B(unit 2)

Eggmal Control Range (0 to +60 in.)

LI-3-53 & 206 TI-80-34-6 0 300 LI-3-60 Average of ,

TI-80-34-7 & 8

• Shutdown Vessel Floodinz Range ,

o +400 in.)

LI-3-55 TR-80-1-10(units ij 10 in. 140 deg F TR-80-1-9(units 2,3) 15 in. 180 deg F 20 in. 210 deg F 25 in. 240 deg F 30 in. 270 deg F 35 in. 300 deg F

• Indicates differences between units.

Page 46 of 378

CAUTION #2 Level instruments LI-3-46A, B (units 1, 3) and LI-3-58A, B (unit 2) are not reliable during rapid Rx depressurization below 500 psig. For these conditions, use other water level instruments to monitor Rx water level.

CAUTION #3 Operating HPCI' turbine below 2400 rpm (minimum turbine speed limit per system test experience) or RCIC turbine below 2100 rpm (minimum turbine speed limit per turbine vendor manual) may result in unstable system operation and equipment damage.

CAUTION #4 Elevated suppression chamber pressure may trip the RCIC turbine on high exhaust pressure.

CAUTION #5 A rapid increase in injection into the Rx may induce a large power excursion and result in substantial core damage.

Page 47 of 378 , , , , ,

EX_Q0NTROL GUIDELINE PURPOSE-The purpose of this guideline is to:

- . Maintain adequate core cooling,

- Shut down the reactor, and

- Cool down the Rx to cold shutdown conditions (Rx water temperature less than or equal to 212*F).

ENTRY CONDITIONS The entry conditions for this guideline are any of the following:

- Rx vater level below +11 inches (low level scram setpoint).

- Rx pressure above 1043 psig (high Rx pressure scram setpoint).

- Drywell pressure above 2.45 psig (high drywell pressure scram setpoint).

- A condition which requires a Rx scram, and Rx power above 3% (APRM downscale trip) or cannot be determined.

- A condition which requires an MSIV isolation.

OPERATOR ACTIONS Irrespective of the entry condition, execute steps RC/L, RC/P, and RC/Q concurrently.

Page 48 of 378 ,, ,

RC/L Monitor and control Rx water level.

1. 1, #2 RC/L-1 Initiate each of the following which should have initiated but did not:

_PCIS Group 1 Isolation

- PCIS Group 2 Isolation

- PCIS Group 3 Isolation PCIS Group 8 Isolation HPCI RCIC Core Spray LPCI, placing the applicable RHRSW pump (s) in service as soon as possible If while executing step RC/L-2:

- Any control rod is not inserted to or beyond posicion 02 (Maximum Suberitical Banked Withdrawal Position), disable ADS auto blowdown function and enter the procedure developed from CONTINGENCY 5.

- Rx water level cannot be determined, enter the procedure developed from CONTINGENCY 2.

RC/L-2 Restore and maintain Rx water level between +11 in. (low level scram setpoint) and +54 in. (high level trip setpoint) with one or more of the following systems:

- Condensate /feedwater

- CRD

- RCIC with suction from the condensate storage tank, defeating low Rx pressure isolation interlocks, if #3, #4 necessary.

- HPCI with suction from the condensate storage tank, defeating high suppression pool water level suction #3 transfer logic if suppression pool temperature is greater than 140 degrees F.

I l

Page 49 of 378 l - ..-

- CS, control and maintain pump flow belod the CS pump NPSH limit (see Figure H)

- LPCI, control and maintain pump flow below the RHR pump NPSH limit (see Figure B); place the applicable RHRSW pump (s) in service as soon as possible RC/L-2.1 If Rx water level cannot be restored and mainth.ned above +11 in. (low level scram setpoint), maintain Rx water level above 0 in, on Post Accident Flooding Range instruments (top of active fuel).

1. Rx water level control may be augmented by one or more of the following systems:

- Condensate transfer pumps to RHR and CS 0 to 100 psig, O to 1000 gpm

- SLC (test tank) augmented by demineralized water head tank 0 to 1400 psig, 23 gpm test tank capacity - 210 gallons demineralized water tank capacity - 30,000 gallons

- SLC (boron tank)

O to 1400 psig, 50 gpm storage tank capacity - 4500 gallons

- RHR crosstie to other units 0 to 310 psig, O to 5000 gpm

- Standby coolant 0 to 160 psig, O to 3500 gpm

, - RHR drain pumps 0 to 40 psig, O to 600 gpm

- PSC head tank pumps 0 to 40 psig, O to 80 gpm

- RCIC (using aux, boiler steam) aux. boiler steam pressure O to 250 psig Rx pressure O to 350 psig, 600 gpm

- HPCI (using aux, boiler steam) aux, boiler steam pressure O to 250 psig Rx pressure O to 350 psig, 5000 gpm Page 50 of 378

RC/L-2.2 If Rx water level can be maintained above 0 in. on Post Accident Flooding Range instruments (top of active fuel) and the ADS timer has initiated, prevent automatic Rx depressurization by resetting the ADS timer.

If Rx water Itvel cannot be maintained above 0 in on Post Accident Flooding Range instruments (top of active fuel), disable ADS auto blowdown function and enter the procedure developed from CONTINGENCY 1.

RC/L-3 When GOI-100-12 (procedure for cooldown to cold shutdown conditions) is entered from step RC/P-5, proceed to cold shutdown in accordance with G0I-100-12 (procedure for cooldown to cold shutdovu conditions).

Page 51 of 378 , , , , ,

RC/P Monitor and control Rx pressure.

If while executing steps RC/P-1 through RC/P-5:

- A high drywell pressure ECCS initiation signal [2.45 psig (drywell pressure which initiates ECCS)] exists, prevent injection from those CS and LPCI pumps not required to assure adequate core cooling prior to depressurizing below 320 psig (LPCI and CS punps shutoff head).

- Emergency Rx depressurization is anticipated and all control rods are inserted to or beyond position 02 (Maximum Suberitical Banked Withdrawal Position), rapidly depressurize the Rx with the main #2 turbine bypass valves.

- Emergency Rx depressurization is required, enter the procedure developed from CONTINGENCY 2.

- Rx water level cannot be determined, enter the procedure developed from CONTINGENCY 2.

RC/P-1 If any SRV is cycling, manually open SRVs until Rx pressure drops to 931.3 psig (Rx pressure at which all main turbine bypass valves are fully open).

If while executing steps RC/P-2 through RC/P-5:

- Steam Cooling is required, enter the procedure developed from CONTINGENCY 3.

If while executing stepr RC/P-2 through RC/P-5:

- Boron injection is required, and

- The main condenser is available, and

- There has been no indication of gross fuel failure or steam line break, apen MSIVs, bypassing Group I isolation and Rx building ventilation isolation interlocks if necessary, to re-establish the main condenser as a heat sink.

Page 52 of 378 , ,

RC/P-2 Stabilize Rx pressure below 1043 psig (high Rx pressure scram setpoint) with the main turbine bypass valves.

RC/P-2.1 Rx pressure control may be augmented by one or more of the following systems:

- $RVs only when suppression pool water level is above 5.5 ft.

(elevation of top of SRV discharge device); open SRVs in a sequence which will equalize heat distribution to the suppression pool (recommended SRV opening sequence); if Drywell Control Air AUD Control Air are or become unavailable, place the control switch for each SRV in the CLOSE or AUTO position.

Recommended SRV Opening Seauence

1) PCV-1-179 8) PCV-1-19

2) PCV-1-180 9) PCV-1-5

3) PCV-1-4 10) PCV-1-41

4) PCV-1-31 11) PCV-1-22

5) PCV-1-23 12) PCV-1-18

6) PCV-1-42 13) PCV-1-34

7) PCV-1-30 HPCI with suction from the CST if I possible. #3

- RCIC with suction from the CST if possible. #3, #4

- Steam line drains RWCU (blowdown mode) only if no boron has been injected into the Rx and no gross fuel failure is suspected.

- RWCU (recirculation mode) only if no boron has been injected into the Rx.

- RFPT and RFPT drains

- Other steam driven equipment such as steam seals, SJAEs, and off gas preheaters.

Page 53 of 378 , , , ,

If while executing steps RC/P-3 through RC/P-5 the reactor is not shutdown, return to step RC/P-2.

RC/P-3 When either:

all control rods are inserted to or beyond position 02 (Maximum Suberitical Banked Withdrawal Position), or 669 pounds of boron (Cold Shutdown Boron Weight) have been injected into the Rx, or the Rx is shutdown and no boron has been injected into the Rx depressurize the Rx and maintain cooldown rate below 100 degrees F per hour (Rx cooldown rate LCO).

RC/P-3.1 If one or more SRVs are being used to depressurize the Rx and Drywell Control Air AND Control Air become unavailable, depressurize with sustained SRV opening.

RC/P-4 When the shutdown cooling interlocks clear, initiate shutdown cooling using only those RHR pumps not required to assure adequate core cooling by continuous operation in the LPCI mode.

RC/P-4.1 If shut'own cooling cannot be established and further cooldown is required, continue to cool down using one or more of the systems used for depressurization.

EC/P-5 When all control rods are inserted to or beyond position 02 (Maximum Suberitical Banked Withdrawal Position) or 669 pounds of boron (Cold Shutdown Boron Weight) have been injected into the Rx, proceed to cold shutdown in accordance with G0I-100-12 (procedure for cooldown to cold shutdown conditions).

Page 54 of 378 ,, ,

t

. RC/Q M:nitor and centrol Rx power.

RC/Q-1 If a Rx scram has not been initiated, initiate a Rx scram.

If while executing steps RC/Q-1.1 through RC/Q-5:

- All control rods are inserted to or beyond position 02 (Maximum Suberitical Banked Withdrawal Position), terminate boron injection and enter GOI-100-11 (scram procedure).

- The Rx is shutdown and no boron has been injected into the Rx, enter G0I-100-11 (scram procedure).

RC/Q-1.1 Verify or place the Rx mode switch in SHUTDOWN.

RC/Q-2 If the main turbine-generator is on-line and the MSIVs are open, verify or initiate recirculation flow runback to minimum.

RC/Q-3 If Rx power is above 3% (APRM Downscale Trip) or cannot be determined, trip the recirculation pumps.

RC/Q-3.1 If the main condenser is not available as a heat sink or heat is being added to the suppression pool, place all available RHR loops in the suppression pool cooling mode using only those RER pumps not required to assure adequate core cooling by continuous operation in the LPCI mode.

Execute steps RC/Q-4 and RC/Q-5 concurrently.

RC/Q-4 If the Rx cannot be shutdown before suppression pool temperature reaches 110 degrees F (Boron Injection Initiation Temperature), BORON INJECTION IS REQUIRED; inject boron into the Rx with SLC and disable ADS auto blowdown function.

RC/Q-4.1 If boron cannot be injected with SLC, inject boron into the Rx by one or more of the following alternate methods:

- RCIC

- RWCU RC/Q-4.2 If boron is not being injected into the Rx by RWCU, verify automatic isolation of or manually isolate RWCU.

Page 55 of 378 , ,

y - - , - - - , - , - - , - y + _ . - - v - r

If while executing steps RC/Q-4.3 through RC/Q-4.4 SLC tank level drops to 0%, manually trip the SLC pumps.

RC/Q-4.3 Continue to. inject boron until 669 pounds (Cold Shutdown Boron Weight) of boron have been injected into the Rx.

RC/Q-4.4 When 669 pounds of Boron (Cold Shutdown Boron Weight) have been injected into the Rx, enter GOI-100-ll (scram procedure).

RC/Q-5 Insert control rods as follows:

RC/Q-5.1 If any scram valve is not open:

1. Remove:

Panel 9-15 5A-F18A, E, C, G Panel 9-17 SA-F18B, F, D, H (fuses which de-energize RPS scram solenoids)

2. Close 85-331 (scram air header isolation valve) and open the instrument drain valves for instruments PS-85-38 and PI-85-38 (scram air header vent valves).

When control

• rods are not moving inwardt

1. Replace:

Panel 9-15 SA-Fl'8A, E, C, G Panel 9-17 5A-F18B, F, D, H (fuses which de-energize RPS scram solenoids)

2. Close the instrument drain valves for instruments P3-85-38 and PI-85-38 (scram air header vent valves) and open 85-331 (scram air header isolation valve).

RC/Q-5.2 Reset the Rx scram. If the Rx scram cannot be reset, continue in this procedure at step RC/Q-5.5, Page 56 of 378

RC/Q-5.3 Drsin tha scram discharge volums, verify or opsn 85-586 (CRD Charging Water Header Isolation Valve), and initiate a manual scram.

1. If control rods moved inward, return to step RC/Q-5.2.

2. Reset the Rx scram. If the Rx scram cannot be reset, continue in this procedure at step RC/Q-5.5.

3. Verify or open the scram discharge volume vent and drain valves.

RC/Q-5.4 Individually open the scram test switches for control rods not inserted to or beyond position 02 (Maximum Suberitical Banked Withdrawal Position).

1. When a control rod is not moving inward, close its scram test switch.

RC/Q-5.5 Manually insert control rods as follows:

If while executing steps RC/Q-5.5.1 through RC/Q-5.5.4 the Rx scram can be reset and control rods moved inward following the last scram, reset the Rx scram and return to step RC/Q-5.3.

1. Align and place in service all available CRD pumps.

If no CRD pump can be started, continue in this guideline at step RC/Q-5.5.4.

2. Close 85-586 (CRD Charging Water Header Isolation Vaive).

3. Rapidly insert control rods manually, defeating RSCS interlocks if necessary.

4. If any control rod cannot be inserted to or beyond position 02 (Maximum Suberitical Banked Withdrawal Position), locally vent the withdraw line for that control rod to a contained radwaste drain until it is not moving inward.

Page 57 of 378

-,-.-.v.- yv- - _ - . .-

PRIMARY CONTAINMENT CONTROL GUIDELINE I

PURPOSE The purpose of this guideline is to:

- Maintain primary containment integrity, and

- Protect equipment inside the primary containment ENTRY CONDITIONS The entry conditions for this guideline are any of the following:

- Suppression pool temperature above 95 degrees F (most limiting suppression pool temperature LCO)

- Drywell temperature above 160 degrees F (maximum normal operating temperature) '

- Drywell pressure above 2.45 psig (high drywell pressure scram setpoint)

- Suppression pool water level above -1 in. (maximum suppression pool water level LCO)

- Suppression pool water level below -6.25 in. (minimum suppression pool water level LCO)

OPERATOR ACTIONS Irrespective of the entry conditions, execute steps SP/T, DW/I, PC/P, and SP/L concurrently.

Pags 58 of 378 ,, ,,

SP/T Monitor and control suppression pool temperature.

SP/T-1 When suppression pool temperature exceeds 95 degrees F (most limiting suppression pool temperature LCO), operate all available suppression pool cooling using only those RHR pumps not required to assure adequate core cooling by continuous operation in the LPCI mode.

SP/T-2 Before suppression pool temperature reaches 110 degrees F (Boron Injection Initiation Temperature), but only if a Rx scram has not been initiated, initiate a Rx scram.

SP/T-3 If suppression pool temperature cannot be maintained below the Heat Capacity Temperature Limit (see Figure F), maintain Rx pressure below the limit in accordance with the procedure developed from RC/P; enter the procedure developed from the Rx Control Guideline at steps RC/L, RC/P, and RC/Q and execute it concurrently with the procedure developed from this guideline.

SP/T-4 If suppression pool temperature and Rx pressure cannot be restored and maintained below the Heat Capacity Temperature Limit (see Figure F), EMERGENCY RX DEPRESSURIZATION IS REQUIRED.

Page 59 of 378 , ,

l DW/T M:nitor and control drywall temp 2rature.

DW/T-1 When drywell temperature exceeds 160 degrees F (Maximum Normal Operating Temperature), #1 operate all available drywell cooling.

If while executing steps DW/T-2 and DW/T-3 drywell pressure drops below 2.45 psig (high drywell pressure scram setpoint), stop drywell sprays.

DW/T-2 Before drywell temperature reaches 281 degrees F (drywell design ,

temperature) but only if the following conditions exist:

-Suppression chamber temperature and drywell pressure are within the Drywel.1 Spray Initiation Limit (see Figure C) AHD l

-Suppression pool water level is at or below 18 feet (elevation of bottom of internal suppression chamber to drywell vacuum breakers less vacuum breaker opening pressure in feet of water)

DW/T-2.1 Shut down reactor recirculation pumps.

DW/T-2.2 Shut down drywell blowers.

DW/T-2.3 Initiate drywell sprays using only those RHR pumps not required to assure adequate core cooling by continuous operation in the LPCI mode.

DW/T-3 If drywell temperature cannot be maintained below 281 degrees F (drywell design temperature), EMERGENCY RX DEPRESSURIZATION IS REQUIRED; enter the procedure developed from the Rx Control Guideline at steps RC/L, RC/P, and RC/Q and execute it concurrently with the procedure developed from this guideline.

Page 60 of 378

- - - - _

• m ,-e, - - ,.--m.- , -- c, -

PC/P M:nitor and control primary containment prensura.

PC/P-1 Operate the following systems as required:

- Containment Atmosphere Dilution

- Standby Gas Treatment System only when the temperature in the space to be evacuated is below 212 degrees F (Maximum Noncondensible Evacuation Temperature).

PC/P-1.1 Verify or place in service H /02 2 Analyzers.

PC/P-1.2 If a group 6 isolation exists, use keylock bypass switch on H2 /02 analyzer panels to monitor drywell and suppression chamber concentrations.

PC/P-1.3 If hydrogen is indicated, refer to OI-84 (procedure for controlling H2 concentration).

If while executing steps PC/P-2 through PC/P-6 suppression pool sprays have been initiated and suppression chamber pressure drops below 2.45 psig (high drywell pressure scram setpoint), stop suppression pool sprays.

PC/P-2 Before suppression chamber pressure reaches 14.5 psig (Suppression Chamber Spray Initiation Pressure) but only if, suppression pool water level is below 20 ft. (elevation of suppression pool spray nozzles),

initiate suppression pool sprays using only those RHR pumps not required to assure adequate core cooling by continuous operation in the LPCI mode.

If while executing steps'PC/P-3 through PC/P-6 drywell sprays have been initiated and dryvell pressure drops below 2.45 psig (high drywell pressure scram setpoint), stop drywell sprays.

Page 61 of 378

PC/P-3 If suppression chambar.preasure exessda 14.5 paig (Suppression Chamber Spray Initiation Pressure) but only if the following conditions exist:

-Suppression chamber temperature and drywell pressure are within the Dryvell Spray Initiation Limit (see Figure C) AHD

-Suppression pool water level is below 18 feet (elevation of bottom of internal suppression chamber to drywell vacuum breakers less vacuum breaker opening pressure in feet of water)

PC/P-3.1 Shut down reacter recirculation pumps.

PC/P-3.2 Shut down dryvell blowers.

PC/P-3.3 Initiate drywell sprays using only those RHR pumps not required to assure adequate core cooling by continuous operation in the LPCI mode.

PC/P-4 If suppression chamber pressure cannot be maintained below the Pressure Suppression Pressure Limit (see figure D), EMERGENCY RX DEPRESSURIZATION IS REQUIRED; enter the procedure developed from the Rx Control guideline at steps RC/L, RC/P, and RC/Q and execute it concurrently with the procedure developed from this guideline.

PC/P-5 If suppression chamber pressure exceeds 55 psig (Primary Containment Pressure Limit), then irrespective of the offsite radioactivity release rate, vent the primary containment, defeating isolation interlocks if necessary, to reduce and maintain pressure below 55 psig (Primary Containment Pressure Limit) as follows:

PC/P-5.1 If suppression pool water level is below 20 ft. (elevation of the bottom of the suppression chamber vent), vent the suppression chamber.

PC/P-5.2 If suppression pool water level is above 20 ft. (elevation of the bottom of the suppression chamber vent) or if the suppression chamber cannot be vented, vent the drywell.

PC/P-6 If suppression chamber pressure cannot be maintained below 55 psig (Primary Containment Pressure Limit), then irrespective of whether adequate core cooling is assured:

PC/P-6.1 If suppression pool water level is below 20 ft. (elevation of suppression pool spray nozzles), initiate suppression pool sprays.

Page 62 of 378

PC/P-6.2 If the folicwing conditions exists

-Suppression chamber temperature and drywell pressure are

~

'within the Drywell Spray Initiation Limit (see Figure C)

AHQ

-Suppression pool water level is below 18 feet (elevation of bottom of internal suppression chamber to drywell vacuum breakers less vacuum breaker opening pressure in feet of water)

1. Shut down reactor recirculation pumps.

2. Shut down dryvell blowers.

3. Initiate dryvell sprays.

4 P f Page 63 of 378

SP/L Monitor and control suppression pool water level.

SP/L-1 Maintain suppression pool water level between -1 in. (Maximum Suppression Pool Water Level LCO) and -6.25'in. (Minimum Suppression Pool Water Level LCO). Instruct Chemistry to sample the suppression pool prior to discharging water from the suppression pool.

SP/L-1.1 If suppression pool water level cannot be maintained above

-6.25 in. (Minimum Suppression Pool Water Level LCO),

execute step SP/L-2.

SP/L-1.2 If suppression pool water icvel cannot be maintained below

-1 in. (Maximum Suppression Pool Water Level LCO), execute step SP/L-3.

SP/L-2 Suppression pool water level below -6.25 in.

(Minimum Suppression Pool Water Level LCO)

Execute sters SP/L-2.1 e.nd SP/L-2.2 concurrently.

SP/L-2.1 Maintain suppression pool water level above the Heat Capacity Level Limit (see Figure E).

1. If suppression pool water level cannot be maintained above the Heat Capacity Level Limit (see Figure E),

EMERGENCY RX DEPRESSURIZATION IS REQUIRED; enter the procedure developed from the Rx Control guideline at steps RC/L, RC/P, and RC/Q and execute it concurrently with the procedure developed from this guideline.

SP/L-2.2 Maintain suppression pool water level above 12.75 ft. (elevation of the top of the HPCI exhaust).

1. If suppress' ion pool water level cannot be maintained above 12.75 ft. (elevation of the top of the HPCI exhaust), secure HPCI irrespective of whether adequate core cooling can be assured.

Page 64 of 378

SP/L-3 Suppression pool water level above -1 in. (Maximum Suppression Pool Water Level LCO)

Execute steps SP/L-3.1 and SP/L-3.2 concurrently.

SP/L-3.1 Maintain suppression pool water level below the Suppression Pool Load Limit (see Figure G).

1. If suppression pool watel level cannot be maintained below the Suppression Pool Load Limit (see Figure G), maintain Rx pressure below the limit in accordance with the procedure developed from RC/P; enter the procedure developed from the Rx Control Guideline at steps RC/L, RC/P, and RC/Q and execute it concurrently with the procedure developed from this guideline.

2. If suppression pool water level and Rx pressure cannot be maintained below the Suppression Pool Load Limit (see Figure G), but only if adequate core cooling is assured, terminate injection into the Rx from sources external to the primary containment except from boron injection systems and CRD.

3. If suppression pool water level and Rx pressure cannot be restored and maintained below the Suppression Pool Load Limit (see Figure G), EMERGENCY RX DEPRESSURIZATION IS REQUIRED.

If while executing steps 3P/L-3.2.1 through SP/L-3.2.3:

- Drywell sprays have been initiated and drywell pressure drops below 2.45 psig (high drywell pressure scram setpoint),

stop drywell sprays.

Page 65 of 378

SP/L-3.2 Beforo suppression pcol vster level reachen 18 ft. (elevation of bottom of suppression chamber to drywell vacuum breakers less vacuum breaker opening pressure in feet of water) but only if adequate core cooling is assured, terminate injection into the Rx from sources external to the primary containment except from boron injection systems and CRD.

1. When suppression pool water level reaches 18 ft. (elevation of bottom of suppression chamber to drywell vacuum breakers less vacuum breaker opening pressure in feet of water) but only if suppression chamber temperature and drywe'll pressure are within the Drywell Spray Initiation Limit (see Figure C):

-Shut down reactor recirculation pumps.

-Shut down drywell blowers.

-Initiate drywell sprays using only those RHR pumps not required to assure adequate core cooling by continuous operation in the LPCI mode.

Execute steps SP/L-3.2.2 and SP/L-3.2.3 concurrently.

2. While cuppression pool water level is above 18 f t.

(elevation of bottom of suppression chamber to drywell vacuum breakers less vacuum breaker opening pressure in feet of water), do not initiate but, if initiated previously, continue to operate drywell sprays until drywell pressure is  ;

below 2.45 psig (high drywell pressure scram setpoint) using only those RHR pumps not required to assure adequate core cooling by continuous operation in the LPCI mode.

3. When primary containment sater level reaches 108 ft.

(Maximum Primary Containment Water Level Limit), stop injection into the Rx from sources ' external to the primary containment irrespective of whether adequate core cooling is assured.

Page 66 of 378

SECONDARY CONTAINMENT CONTROL GUIDELINE EURE01E The purpose of this guideline is to:

- Protect equipment inside the secondary containment,

- Limit radioactivity release to the secondary containment, and either:

- Maintain secondary containment integrity, or

- Limit radioactivity release from the secondary containment.

ENTRY CONDITIONS The entry conditions for this guideline are any of the following secondary containment conditions:

- Differential pressure at or above 0 in. of water

- An area temperature above the maximum normal operating temperature

- A Reactor or Refuel Zone ventilaticn exhaust radiation level above the maximum normal operating radiation level.

- An area radiation level above the maximum normal operating radiation level

- A floor drain sump water level above the maximum normal operating water level

- An area water level above the maximum normal operating water ' level Page 67 of 378

0?ERATOR ACTICMS If while executing steps SC/T-1 through SC/T-4:

- Reactor zonc ventilation exhaust radiation level exceeds 72 ar/hr (isolation setpoint), confirm or manually initiate isolation of reactor zone and refuel zone ventilation, and confirm initiation of or manually initiate SGTS. l

- Re- el zone ventilation exhaust rtdiation level exceeds 67 mr/hr (isolatica setpoint), confirm or manually initiate isolation of refuel zone ventilation, and confirm initiation of or manually initiate SGTS.

I If while vecuting steps SC/T-1 through SC/T-4:

- Reacto; zone or refuel zone ventilatlon isolates, and

- Reacto zone ventilstion enhaust radiation level is belov 72 mr/hr (high radiatic' isoihtion setpoint) or refue.1 zone ventilation exhaust radiation level is below 67 mr/hr (high radiz *on isolation

.itpoint)

, restart reactor zone or refuel zone ventilation, defeating high dry-

.'rell oressure and lov Rx water level isols.lon interlocks if necessary 64 If Rn butiding to outside air differential pressure is greater than or equal to 0 inches of water, verior running all available reactor

, zone and refuel zone ventilation or manually initir.te SGTS.

T Irrespective of the entry condition, execute steps SC/T, SC/R, and SC/L concurrently.

. - ~

Page 68 of 378

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SC/T Monitor and control secondary containmInt tecparatursc.

SC/T-1 If reactor zone ventilation exhaust radiation level is below 72 mr/hr

- (isolation setpoint) or refuel zone ventilation exhaust raciation level is below 67 mr/hr (isolation setpoint), operate available reactor zone or refuel zone ventilation.

SC/T-2 When an area temperature excee ls its maximum normal operating temperature, isolate al) systems that are discharging into the area except system required to shut down the reactor, assure adequate core cooling, or suppress a fire.

l Execute steos SC/T-3 and SC/T-4 concurrent 1v. I SC/T-3 If a primary system is discharging into secondary containment:

SC/T-3.1 Before any area temperature reaches its maximum safe operating temperature, enter the procedure developed from th'e Rx Control Guideline at steps RC/L, RC/P, and RC/Q and execute it concurrently with the procedure developed from this guideline.

SC/T-3.2 When an area temperature exceeds its maximum safe operating temperature in more than one area, EMER9ENCY RX DEPRESSURIZATION IS REQUIRED.

SC/T-4 When an area' temperature exceeds its maximum safe operating temperature in more than ont area, shut down the reactor in accordance with GOI-100-12 (procedure for shutdotn from power and cooldown to cold shutdown conditions).

Ps-e 69 of 378 ,,

9 w r

SC/R Monitor and control secondary containmInt radicticn 10vels.

SC/R-1 When an area radiation level exceeds its maximum normal operating radiation level, isolate all systems that are dischaiging into the area except systems required to shut down the reactor, assure adequate core cooling, or suppress a fire.

~

l EE.cutesteDsSC/R-2andSC/R-3concurrentiv. l SC/R-2 If a primary system is discharging into secondary containment:

SC/R-2.1 Before any area radiation level reaches its maximum safe operating radiation level, enter the procedure developed from the Rx Control Guideline at steps RC/L, RC/P, and RC/Q and execute it concurrently with the l

procedure developed from this guideline.

SC/R-2.2 When an area rediation level exceeds its maximum safe 1 operating radiation level in more than one area, EMERGENCY RX DEPRESSURIZATION IS REQUIRED.

i SC/R-3 When an area radiation level exceeds its maximum safe operating radiation level in more than one area, shut down the reactor in accordance with GOI-100-12 (procedure for shutdown from power and cooldown to cold shutdown conditions).

1 1

l ,.

l l

i Page 70 of 378

SC/L Monitor and control secondary containment water levelc.

SC/L-1 When a floor drain sump or area water level is above its maximum normal operating water level, operate available sump pumps to restore and maintain it below its maximum normal operating water level.

SC/L-1.1 If any floor drain sump or area water level cannot be restored and maintained below its ma.-imum normal operating water level, isolate all systems that are discharging water into the sump or area except systems required to shut down the reactor, assure adequate core cooling, or suppress a fire.

I Execute steos SC/L-2 and SC/L-3 concurrent 1v. _}

SC/L-2 If a primary system is discharging into secondary containment:

SC/L-2.1 Before any area water level reaches its maximum safe operating water level, enter the procedure developed from the Rx Control Guideline at steps RC/L, RC/P, and RC/Q and execute it concurrently with the procedure developed t from this guideline.

SC/L-2,2 When an area water level exceeds its maximum safe operating water level in more than one area, EMERGENCY RX DEPRESSURIZATION IS REQUIRED.

SC/L-3 When an area water level exceeds its maximum safe operating water level in more than one area, shut down the reactor in accordance with GOI-100-12 (procedure for shutdown from power and cooldown to cold shutdown conditions).

Page 71 of 378 9

Cl-4 RX WATER LEVEL INCREASING, RX PPESSURE GREATER THAN 320 PSIG Cl-4.1 Enter,the procedure developed from the Rx Control Guideline at' step RC/L.

Cl-5 RX WATER LEVEL INCREASING, RX PRESSURE BETWEEN 320 AND 100 PSIG Cl-5.1 If HPCI and RCIC are not operating and Rx pressure is increasing, EMERGENCY RX DEPRESSURIZATION IS REQUIRED.

1. When Rx pressure is decreasing, enter the procedure developed from the Rx Control Guideline at step RC/L.

Cl-5.2 If HPCI and RCIC are not operating and Rx pressure is not increasing, enter the procedure developed from the Rx Control guideline at step RC/L.

Cl-5.3 Otherwise, when Rx water level reaches +11 in. (low level scram setpoint), enter the procedure developed from the Rx Control Guideline at step RC/L.

Cl-6 RX WATEk LEVEL INCREASING, RX PRESSURE LESS THAN 100 PSIG Cl-6.1 if Rx pressure is increasing, EMERGENCY RX DEPRESSURIZATION IS REQUIRED.

1. When Rx pressure is decreasing, enter the procedure developed from the Rx Control Guideline at step RC/L.

Cl-6.2 Otherwise, enter the procedure developed from the Rx Control Guideline at step RC/L. ,

'i.-7 RX WATER LEVEL DECREASING, RX PRESSURE GREATER THAN 100 PSIG Cl-7.1 If HPC1, RCIC, or CRD is not operating, restart whichever is not operating. #3, #4 Cl-7.2 If no :jection subsystem is lined up for injection with at least one pump running, start pumps in alternate injection subsystems which are lined up for injection.

Page 79 of 378 , ,

+

C1-7.3 When Rx water level drops to 0 in. on Post Accident Flooding Range Instrument (top of active fuel):

1. If no system, injection subsystem, or alternate injection subsystem is lined up with at least one pump running, STEAM-COOLING IS REQUIRED.

- When any system, injection subsystem, or alternate injection subsystem is lined up with at least one pump running, return to step Cl-3.

2. Otherwise, EMERGENCY RX DEPRESSURIZATION IS REQUIRED.

- When Rx water level is increasing or Rx pressure drops below 100 psig (HPCI low pressure isolation se point), return to step Cl-3.

Cl-8 RX WATER LEVEL DECREASING, RX PRESSURE LESS THAN 100 PSIG C1-8.1 Line up for injection, start pumps, and irrespective of pump NPSh' limits, i'ncrease injection flow to the maximum with all systems and injection subsystems.

Cl-8.2 When Rx water level drops to 0 in on Post Accident Flooding Range Instruments (top of active fuel), EMERGENCY RX DE;'ESSURIZATION IS REQUIRED.

1. Line up for injection, start pumps, and increase injection flow to the maximum with all alternate injection subsystems. ,

C1-8.3 If Rx water level cannot be restored and maintained above 0 in. on Post Accident Flooding Range Instruments (top of active fuel), enter the procedure developed from CONTINGENCY 7.

i i

l 1

Page 80 of 378 , ,

CONTINGENCY #2 EMERGENCY RX DEPRESSURIZATION C2-1 When either:

1. 2

- Any control rod is not inserted to or beyond position 02 (Maximum Suberitical Banked Withdrawal Positien) and all injection into the Rx except from boron injection systems and CRD has been stopped and prevented, or

- All control rods are inserted to or beyond position 02 (Maximum Suberitical Banked Withdrawal Position)

C2-1.1 lf a high drywell pressure ECCS initiation signal (2.45 psig (dryvell pressure which initiates ECCS)] exists, prevent injection from those CS and LPCI pumps not required to assure adequate core cooling.

C2-1.2 If suppression pool water level is above 5.5 f t. (elevation of top of SRV discharge device):

1. Open all ADS valves.

2. If any ADS valve cannot be opened, open other SRVs until a total of six (number of SRVs dedicated to ADS) valves are open.

C2-1.3 If less than three (Minimum Number of SRVs Required for Emergency Rx Lepressurization) SRVs are open and Rx pressure is at least 50 psig (Minimum SRV Re-opening Pressure) above suppression cham'er o pressure, rapidly depressurize the Rx, defeating isolation interlocks if necessary, using one or more of the following systems:

- Main condenser, bypassing MSIV and main steam line drain low-low-low water 1evel isolation interlocks

- Other steam driven equipment such as steam seals, SJAEs, off gas preheater

- Main steam line drain bypassing MSIV and main steam line drain low-low-low water level isolation interlocks

- HPCI, bypassing test mode interlocks Page 81 of 378 , ,_

- RCIC, bypassing tast mode interlocks, RCIC low pressure isolation interlocks, and high level trip logic

- Rx h'ead vent If Rx water level cannot be determined, enter the procedure developed from CONTINGENCY 4.

C2-2 Enter the procedure developed from the Rx Control Guideline at step RC/P-4.

4 I

Page 82 of 378

CONTINGENCY #3 STEAM COOLING C3-1 Make continued attempts to get injection systems, injection subsystems, or alternate injection subsystems lined up for injection with at least one pump running.

If while executing steps C3-1.1 and C3-1.22

- Emergene:? Rx Depressurization is required, or

- Rx water level cannot be determined, or

- Any -injection system, injection subsystem, or alternate injection subsystem is lined up for injection with at least one pump running, enter the procedure developed from CONTINGENCY 2.

C3-1.1 When Rx water level drops to -100 in, on Post Accident Flooding Range Instruments (Minimum Zero-Injection Rx Water Level),

open one SRV. 2 C3-1.2 When Rx pressure drops below 700 psig. (Minimum Single SRV Steam Cool'..g Pressure), enter the procedure developed from CONTINGENCY 2.

Page 83 of 378 , ,_

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CONTINGENCY #4 RX FLOODING If while executing steps C4-1 through C4-5 Rx water level can be determined:

- If any control rod is not .nserted to or beyond position 02 (Maximum Suberitical Banked Withdrawal Position), disable ADS auto blowdown function and enter the procedure developed from CONTINGENCY 5 and the procedure developed from the Rx Control Guideline at step RC/P-4 and execute these procedures concurrently.

- If all control rods are inserted to or beyond position 02 (Maximum Suberitical banked Withdrawal Position), enter the procedure developed from the Rx Control Guideline at steps RC/L and RC/P-4 and execute these procedures concurrently.

C4-1 If any control rod is not inserted to or bcyend position 02 (Maximum Suberitical Banked Withdrawal Position), flood the Rx as follows:

C4-1.1 Stop and prevent all injecticn into the Rx except from boron injection systems and CRD until Rx pressure is below the Minimum Alternate Rx Flooding Pressure.

Minimum Alternate Rx Number of Open SRVs Floodina Pressure (osin) 6 or more 190 5 210

. 4 260 3 320 2 ,, 440 1 830

1. If less than one (minimum number of SRVs for which the Minimum Alternate Rx Flooding Pressure is below the lowest SRV lifting pressure) SRV can be opened, continue in this guideline.

Page 84 of 378

C4-1.2 If at least three (Minimum Number of SRVs Required for Emergency Depressurization) SRVs can be opened:

1. Close the MSIVs.

4

2. Close the main stcam line drains.

8

3. Close the RCIC steam line isola tion valves.

CA-1.3 Commence and, irrespective of pump NPSH limits, slowly increase injection into the Rx with the following systems until at least one (minimum #5 number of SRVs for which the Minimum Alternate Rx Flooding Pressure is below the lowest SRV lifting pressure) SRV is open and Rx pressure is above the Minimum Alternate Rx Flooding Pressure:

- Condensate

- CRD

- LPCI, bypassing RHR injection valve timers if necessary; place applicable RHRSW pump (s) in operation as soon as possible C4-1.4 If at least one (minimum number of SRVs for which the Minimum Alternate Rx Flooding Pressure is below the lowest SRV lifting pressure) SRV is not open or Rx pressure cannot be increased to above the Minimus Alternate Rx Flooding Pressure, commence and, e irrespective of pump NPSH limits, slowly increase injection into dhe .

Rx with the following systems until at least one (minimum number of SRVs for which the Minimum Alternate Rx Flooding Pressure is below the lowest SRV lifting pressure) SRV is open and Rx pressure is above the Minimum Alternate Rx Flooding Pressure:

- CS

- Condensate transf,er to RHR and CS

- RHR crosstie to other units

- Standby coolant

- RHR drain pumps

- PSC head tank pumps Page 85 of 378

C4-1.5 If et lenst cne (mininum number of SRVs for which the Minimum Alternate Rx Flooding Pressure is below the lowest SRV lifting pressure) SRV is not open or Rx pressure cannot be increased to above the Minimum Alternate Rx Flooding Pressure, restart RCIC, defeating low Rx pressure isolation interlocks and high Rx water level turbine trip if necessary, and increase injection flow to the maximum.

C4-1.6 When at least one (minimum number of SRVs for which the Minimum Alternate Rx Flooding Pressure is below the lowest SRV lifting pressure) SRV is open and Rx pressure is above the Minimum Alternate Rx Flooding Pressure, control injection to maintain at least one (minimum nitsber of SRVs for which the Minimum Alternate Rx Flooding Pressure is below the lowest SRV lifting pressure) SRV open and Rx pressure above the Minimum Alternate Rx Flooding Pressure but as low as practicable.

C4-1.7 When all control rods are inserted to or beyond position 02 (Maximum Suberitical Banked Withdrawal Position), continue in this guideline.

C4-2 If at least three (Minimum Number of 3RVs Required for Emergency Depressurization) SRVs can be opened:

C4-2.1 Close the MSIVs.

C4-2.2 Close the main steam line drains.

C4-2.3 Close the RCIC steam isolation valves. .

C4-3 Flood the Rx as follows:

C4-3.1 Commence and, irrespective of pump NPSH limits, increase injection into the Rx with the following systems until at least three (Minimum Number of SRVs Required for Emergency Depressurization) SRVs are open and Rx pressure is not decreasing and is 70 psig (Minimum Rx Flooding Pressure) or more above suppression chamber pressure.

- Condensate

- LPCI

- CS

- CRD

- Condensate transfer to RHR and CS

- SLC (test tank)

- SLC (boron tank)

Page 86 of 378 , ,,,

m

- RER crosatie to other units

, - Standby coolant

- RHR drain pumps j

- PSC head tank pumps

- RCIC (using aux. boiler steam)

- HPCI (using aux. boiler steam)

-1. If at' least three (Minimum Number of SRVs Required for Emergency Depressurization) SRVs are not open or Rx pressure cannot be maintained at least 70 psis (Minimum Rx Flooding Pressure) above suppression chamber pressure, restart RCIC, defeating low Rx pressure isolation interlocks and high Rx water level turbine trip if necessary, and increase injection flow to the maximum.

C4-3.2 When at-least three (Minimum Numberlof SRVs Required for Emergency Depressurization) SRVs are open and Rx pressure can be maintained at least 70 pais (Minimum Rx Flooding Pressure) above suppression chamber pressure, control injection to maintain at least three (Minimum Number of SRVs Required for Emergency Depressurization) SRVs open and Rx pressure at lear,t 70 psig (Minimum Rx Flooding Pressure) above suppression chamber pressure but as low as practicable.

4 C4-4 When:

- Rx water level instrumentation is available, and

- Temperatures near the cold reference leg instrument vertical runs-are below 212 degrees F, and

- Rx pressure has remained at least 70 psig (Minimum Rx Flooding Pressure)

, above suppression chamber pressure for at least the Minimum Core Flooding Interval Minimum Core Flaoding Number of Open SRVs Interval in Minutes 6 or more 14 5 21 4 39 3 87 Stop all injection into the Rx and reduce water level until Rx water level indication is restored.

Page 87 of 378 e

C4-4-1 If Rx water icvel indic: tion 10 n:t restorsd within ths Maxinum Cara Uncovery Time Limit after commencing termination of injection into the Rx, return to step C4-3.1.

M uimum Core Uncovery Titne After Rx Shutdown Time Limit 1 min 3 mins 5 min 4 mins 10 min 5 mins 15 min 6 mins 20 min 6 mins 30 min 7 mins 40 min 8 mins 50 min 8 mins 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 9 mins 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 20 mins 10 mins I hour 40 mins 10 mins 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> 16 mins 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> 40 mins 19 m!ns 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> 27 mins 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> 35 mins C4-5 Enter the procedure developed from the Rx Control Guideline at steps RC/L and RC/P-4 and execute these steps concurrently.

l l

Page 88 of 378 , ,

CONTINGENCY ti LEVEL / POWER CONTROL If while executing steps C5-1 through C5-4:

- Rx water level cannot be determined, enter the procedure developed from CONTINGENCY 4.

f

- All control rods are inserted to or beyone 'osition 02 (Maximum Suberitical Banked Withdrawal Position),<. ' the procedure developed from the Rx Control Guideline at > . RC/L.

C5-1 If:

-Rx power is above 3% (APRM downscale trip) or cannot be determined, and

-Suppression pool temperature is above 110 degrees F (Boron Injection initiation Temperature), and

-Either an SRV is open or cycling at setpoint or drywell pressure is above 2.45 psig (high drywell pressure neran setpoint)

Then perform the following:

C5-1.1 If any MSIV is open, bypass MSIV and main steam line drain valve low-low-low level isolation and Rx building ventilation low level isolation interlocks C5-1.2 Lower Rx water level, irrespective of any consequent Rx power oscillations, by stopping and preventing all injection into the Rx except from boron injection systems and CRD until either:

- Rx power drops below 3% (APRM downscale trip), or

- Rx water level reaches 0 in. on Post Accident Flooding Range Instruments (Flow Stagnation kater Level), or

- All SRVs remain closed and drywell pressure remains below 2.45 psig (high drywell pressure scram setpoint).

/

Page 89 of 378

n-If while executing -steps C5-2 through C5-4 Emergency Rx Depressurization is required, continue in this guideline at sten C5-2.2.1.

-If while executing step C5-2 and associated substeps:

- Rx power is above 3% (APRM downscale trip) or cannot be determined, and

- Rx water level is above 0 in. on Post Accident Flooding Range instruments.(Flow Stagnation Water Level), and

- Suppression pool temperature is above 110 degrees F (Boron Injection Initiation Temperature), and

- Either an SRV is open or cycling at setpoint or dryvell pressure ir above 2.45 psig (high drywell pressure scram setpoint) return to step C5-1.

C5-2 Maintain Rx water level either:

1. 5

- If Rx water level was deliberately lowered in step C5-1, at the level to which it was lowered, or

- If Rx water level was not deliberately lowered in C5-1, between +11 in.

(low level scram setpoint) and +54 in. (high level trip setpoint) with the following systems:

- Condensate /feedwater

- CRD

- LPCI, bypass the LPCI injection valve timers if necessary; control and maintain RHR pump flow less than the RHR pump NPSH limit (see Figure B); place applicable RHRSW pump (a) in service as soon as possible.

i Page 90 of 378 4

.4

- RCIC with suction from CST, defeating low Rx pressure isolation interlocks if necessary #3, #4

- HPCI with suction from the CST, defeating high suppression pool water level suction transfer logic interlocks if suppression pool #3 temperature is greater than 140*F.

~

C5-2.1 If Rx water level cannot be so maintained,' maintain Rx water level above 0 in. on Post Accident Flooding Range Instruments (top of active fuel) with the above systems.

C5-2.2 If Rx water level cannot be restored and maintained above 0 in. on Post Accident Flooding Range Instruments (top of active fuel),

EMERGENCY RX DEPRESSURIZATION IS REQUIRED; continue in this guideline at step C5-2.2.1. Otherwise proceed to step C5-3.

1. Stop and prevent all injection into the Rx except from boron injection systemc and CRD until Rx pressure is below the Minimum Alternate Rx Flooding Pressure.

Minimum Alternate Rx Number of Onen SRVs Flooding Pressure (osia) 6 or more 190 5 210 4 260 3 320 2 440 1 830

2. If less than one (minimum number of SRVs for which the Minimum Alternate Rx Flooding Pressure is below the lowest SRV lif ting pressure) SRV can be opened, continue in this guideline.

3. Commence and, irrecpective of pump NPSH limits, slowly increase injection into the Rx with the following rystems to restore and maintain Rx water level above 0 in, on Post Accident Flooding Range Instruments (top of active fuel) but #5 as low as practicable.

- Condensate /feedwater

- CRD Page 91 of 378 e

m .A

7

- RCIC with suction from the CST, defeating low Rx pressure isolation interlocks if necessary

- HPCI with suction from the CST, defeating high suppression pool water level suction transfer logic Interlocks if suppression pool temperature is greater than 140*F.

- LPCI bypassing RHR injection valve timerc if necessary; place applicable RHRSW pump (s) in operation as soon as possible

4. If Rx water level cannot be restored and maintained above 0 in.

on Post Accident Flooding Range Instruments (top of active fuel), commence and, irrespective of pump NPSH limits, slowly increase injection into the Rx with the following systems to restore and maintain Rx water level above 0 in, on Post Accident Flooding Range Instruments (top of active fuel) but as low as practicable:

- CS

- Condensate transfer to RHR and CS 0 to 100 psig, O to 1000 gpm

- SLC (test tank - augmented by demineralized water head tank)

O to 1400 psig, 23 gpm test tank capacity - 210 gallons demineralized water tank capacity - 30,000 gallons makeup available at 23 gpm

- SLC (boron tank)

• 0 to 1400 psig, 50 gpm storage tank capaci*.y - 4500 gallons

- RHR erosstie to other units 0 to 310 psig, O to 5000 gpm

- Standby coolant 0 to 160 psig, O to 3500 gym

- RHR drain pumps 0 to 40 psig, O to 600 gpm

- PSC head tank pumps 0 to 40 psig, O to 80 gpm

- RCIC (using aux. boiler steam) aux boiler steam pressure 0 - 250 psig Rx pressure 0 - 350 psig, 0 - 600 gpm Page 92 of 378 , , , ,

- HPCI (using cux. b2ilor steam) aux. boiler steam pressure 0 - 250 psig Rx pressure 0 - 350 psig, 0 - 5000 spa If while executing step C5-3 and associated substeps reactor power commences and continues to increase, return to step C5-1.

C5-3 When 366 pounds (Hot Shutdown Boron Weight) of boron have been injected, restore and maintain Rx water level between +11 in. (low level scram setpoint) and +54 in. (high level trip setpoint).

C5-3.1 If Rx water level cannot be restored and maintained above +11 in.

(low level scram setpoint), then maintain Rx water level above 0 in.

on Post Accident Flooding Range Instruments (top of active fuel).

C5-3.2 If Rx water level cannot be maintained above 0 in. on Post Accident Flooding Range Instruments (top of active fuel), EMERGENCY RX DEPRESSU"IZATION IS REQUIRED; continue in this guideline at step C5-2.2.1.

C5-4 When GOI-100-12 (procedure for cooldown to cold shutdown conditions) is entered from the procedure developed from the Rx Control Guideline at r ;ep RC/P-5. proceed to cold shutdown in accordance with GOI-100-12 (pcocedure for cooldown to cold shutdown conditions).

' age 93 of 378 - ...

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---_.,__c-- -, ~ r -. ,

CONTINGENCY #7 CORE COOLING WITHOUT LEVEL RESTORATION G7-1 Open all six ADS valves.

C7-1.1 If any ADS valve cannot be opened, open other,SRVs until six (number of SRVs dedicated to ADS) valves ce onen.

C7-2 Operate as many CS pumps as possible, taking suction from the suppression pool and injecting into the Rx.

C7-2.1 When

- At least one CS subsystem is operating with suction from the suppression pool, and

- Rx pressure is below 130 psig (Rx pressure for reted CS flow)

- Rx water level is maintained at or above -48 inches on the post-accident flooding range (two-thirds core height)

Stop injection into the Rx from sources external to the primary containment.

C7-3 hhen Rx water level is restored to 0 in, on Post Accident Flooding Instruments (top of active fuel), enter the procedure developed from the Rx Control Guideline a*, step RC/L.

4 e

Page 94 of 378

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EMERGENCY OPERATING INSTRUCTION WRITERS GUIDE e

Page 103 of 378 6

TABLE OF CONTENTS Section PJuLt 1.0 Introduction . . . . . . . . . . . . . . . . .. . . . . 105 2.0 References .'. . . . . . . . . . . . . . . . . . . . . . 105 3.0 Definitions . . . . . . . . . . . . . . . . . . . . . . .105 4.0 Instructions . . . . . . . . . . . . . . . . . . . . . . 106 4.1 Organization . . . . . . . . . . . . . . . . . . . 107 4.2 Format . . . . . . . . . . . . . . . . . . . . . . 107 4.3 Style . . . . . . . . . . . . . . . . . . . . . . .112 4.4 Content . . . . . . . . . . . . . . . . . . . . . .115 4.5 Typing Instructions . . . . . . . . . . . . . . . .117 5.0 Responsibilities . . . . . . . . . . . . . . . . . . . . 118 6.0 Documentation . . . . . . . . . . . . . . . . . . . . . .118 7.0 Illustrations / Attachments . . . . . . . . . . .. . . .a.118 Attachment 1, Action Verbs . . . . . . . . . . . . . . . 119 Attachment 2, Abbreviations and Acronyms . . . . . . . . 125 Page 104 of 378 , , , _

1.0 INTRODUCTION

1.1 Purcose The purpose of this writer's guide is to provide administrative guidance to aid in the preparation of emergency operating instructions for the Browns Ferry Nuclear Plant.

1.2 Scope This guide is applicable for revision two of the E0I's and all subsequent revisions to the E0I's.

1.3 Objective

. The writer's guide is intended to provide instructions and guidance for i translating the information contained in the Browns Ferry Nuclear Plant Specific Technical Guidelines (BFN-PSTGs) into Emergency Operating Instructions (E0Is). Use of the writers guide will assure that the E0Is are presented in a readable format and are consistent in content and style.

2.0 REFERENCES

2,1 PMI-12.6, Implementation and Maintenance of Emergency Operating Instructions.

2.2 Browns Ferry Nuclear Plant Specific Technical Guidelines.

2.3 BWR Owner's Group Emergency Procedure Guidelines.

2.4 NUREG 0899, Guidelines for the Preparation of Emergency Operating Procedures.

2.5 INPO 82-017, Emergency Operating Procedures Writing Guideline.

3.0 DEFINITIONS Emergency Operatina Instructions Procedures which direct operator actions necessary to mitigate the consequences of transients or accidents that cause plant parameters to exceed reactor protection system setpoints, engineered safety feature setpoints, or other appropriate technical limits.

Page 105 of 378 9

4.0 INSTRUCTIONS 4.1 Orlanization E0I's shall contain the following:

1. Cover Sheet

2. Statement of Purpose

3. List of Entry Conditions

4. List of Operator Actions

5. Procedure Steps

6. Contingency Steps (as needed)

7. Appendices (as needed) 4.1.1 Cover Sheet Each E0I shall be preceded by the standard cover sheet used for all plant procedures. The primary purposes of this cover sheet are to:

1. Identify the E0I by title and number designation for document control.

2. Identify the unit and facility to which the procedure applies.

3. Provide a place for review and approval signatures.

4. Provide a remarks section in which the reason for the most current revision is stated.

Tha cover sheet will not be included in the special book used in the control room and technical support center.

4.1.2 Perpose Each E0I shall have a brief statement describing what the procedure is intended to accomplish.

4.1.3 Entry Conditions Each E0I shall list the conditions under which the procedure should be used.

4.1.4 Operator Actions Each E0I shall state the operator actions or procedures to be performed to execute the E0I.

1 1

Page 106 of 378 9

4.1 C?nanization (Continued) 4.1.5 Parameter Control Procedures Steps which when grouped together accomplish a specific objective (i.e. Reactor Level Control, Drywell Temperature Control, etc.)

are referred to as parameter control procedures.

4.1.6 Contingencies Contingencies provide instructions for plant conditions which are more degraded than those addressed by the guidelines.

Contingencies should describe operator actions to perform specific functions such as emergency reactor depressurization, reactor flooding, etc.

4.1.7 Appendices Appendices contain supplemental information necessary for the operator to have in order to carry out certain actions. This information is in the form of system lineups, component lists, and equipment locations.

4.2 Format 4.2.1 Identifying Information To aid the operator in readily locating specific portions of the E0Is, an identifier will be placed at the top right corner of each page. Identifiers for parameter control procedures, contingencies, and appendices shall uniquely identify these sections.

Identifiers for parameter control procedures shall indicate the objective of the procedure (i.e. RC/L for the Reactor Level Control Procedure, etc.). Identifiers for contingencies shall be of the form CX where X is a numerical value (i.e. C1, C2, etc.).

The appendices will be identified by number (i.e. Appendix 1, Appendix 2, etc.)

All other pages of the E01's which are not included in one of the parameter control procedures, contingencies, or appendices shall have the E0I number as the identifier (i.e. E0I-1, E0I-2, etc.)

In addition to the identifier described above, each page will contain the following:

1. The unit number specified as "UNIT "

2. The revision number.

3. The page number specified as "Page of "

Page 107 of 378 9

. ~4.2 Fo rmat (C ntinuid)

All of the above information will be together at the top right corner of the page using the following format:

Page 1 of 4 E0I-1 Unit 1 Rev 0 Each parameter control procecure, contingency, and appendix contained within the E01's shall be numbered independently (i.e.

RC/L would begin at Page 1 of n and go through Page n of n, RC/P would begin again at Page 1 of n and go through Page n of n, etc.).

4.2.2 Headings Each E01 will contain three major headings numbered as follows:

1.0 PURPOSE 2.0 ENTRY CONDITIONS 3.0 OPERATOR ACTIONS Major divisions under each heading shall be numbered by incrementing the value of the digit following the decimal place (i.e. 1.1, 1.2, etc.).

Further divisions shall be numbered using an additional decimal place and shall be indented.

EXAMPLE: 2.0 Section Heading 2.1 Major Division 2.1.1 Sub-Division 2.1.2 Sub-Division Each parameter control procedure, contingency, and appendix shall have its own heading centered at the top of the first page of the section. All parameter control procedures, contingencies, and appendices shall begin on a new page.

4.2.3 Steps Steps within each parameter control procedure and c.ontingency section of the E0I's shall be identified and numbered as follows:

1. The identifier described in Section 4.2.1 shall precede each step number (Ex: RC/L).

2. Major steps shall be numbered using sequential whole numbers (Ex: RC/L-1).

Page 108 of 378

e 4.2 Format (Ctntinusd)

Notes shall be preceded with the word "NOTE" as shown:

HQIE: If at qny time Rx pressure or water level trend reverses or Rx pressure changes region, return to Step Cl-3.

Cautions and notes will immediately precede the step (s) to which they refer.

Notes and cautions will not be interrupted by intervening steps or page turning.

4.2.5 Charts, Tables, and Diagrams Charts, tables, and diagrams shall be labeled and numbered as follows:

1. Charts shall be labeled as figures and designated by a capital letter. (Ex: Figure A).

2. Figures shall be labeled as such and designated by a numeral (Ex: Figure 1).

3. Logic diagrams shall be labeled as such and numbered using the step number to which they apply. (Ex: C1-3 Logic Diagram).

4. Tables will not be numbered. They will be labeled as to contents and located near the steps to which they apply.

The chart number (fidure number) and title of each chart will be centered above the chart.

Charts will be located on the page of the step in which they are referred, if at all possible. If a calculation must be done to use a chart, the calculation procedure will be placed near the chart to which it applies.

Tables will directly follow the step or caution in which they are referenced or shall be on the facing page. They shall be presented in a columnar format with each column having a title expressing its contents centered above it.

Whenever a change to the E0Is occurs such that the layout of the procedures needs to be changed in th.) five section binder, revise Figure 1, 'E0I Layout', as ne essary to reflect the change.

Page 110 of 378 4

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4.2 Format (Continued) 4.2.6 Appendices In general, the appendices shall be numbered using numerals-for-steps and letters for substeps.

The particular style used for numbering steps is dependent upon '

the nature of the Appendix.

At the beginning of each appendix shall be placed a line of any tools or other hardware needed to execute the steps in that appendix and the storage location of those required tools or ,

other hardware. -

4.2.7 Placekeeping aids Checkoffs shall be used for placekeeping aida, and will be located at the right hand margin for all stepa and cautions.

Checkoffs at the right hand margin may be replaced by a checkoff in another location where necessary for clarification. (Ex:

next to-individual valves in a list).

4.2.8 Emphasis Underlining, capitalizing and boldface lettering shall be used for emphasizing certain words or phrases.

Underlining will be used for the following:

1. All section headings.

2. All "caution" and "note" headings.

3. All logic terms (refer to 4.3.8 of this guide).

4. Miscellaneous words needing special impact.

Capitalization will be used as follows: ,

1. The title of the E0I will be all capital letters whenever it appears in the procedure.

2. wil logic terms will be in capital letters.

3. The words "caution" and "note" will be in capital letters.

4. The words (excluding conjunctions), in titles will be capitalized.

5. Abbreviations of systems and procedures will be in capital letters unless it is confusing. (Ex: Rx) ,

Page 111 of 378 - .. .

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b 4.2 Format (Continued) 6 '. A specific requirement to enter a contingency will be in capital letters (Ex: EMZRGENCY RX DEPRESSURIZATION IS REQUIRED).

7. The rules of standard American English will govern all other uses of capitalization.

Boldface lettering (enhanced print) will be used where necessary to delinate sections and actions.

4.3 Style 4.3.1 Sentence Structure All instruction steps, notes, and cautions shall be written in understandable phrases or complete sentences using a word order common to standard American English usage.

Short, simple centences should be used in preference to long, compound, or complex sentences.

Sentences which require the operator La do something or observe something should be written as a directive.

4.3.2 Punctuation The following guidelines apply to punctuation usage: .

1. Use the rules of punctuation for standard American English.

2. Use pun.,tuation only as necessary to aid reading and prevent misundarstanding.

3. Selest word order which requires a minimum of punctuation.

4. Use a comma'after conditional phrases for clarity and ease  ;

of reading.

Example: LE HPCI or RCIC is not operating, IHEH restart whichever is not operating.

5. Ensure the use of punctuation remains consistent throughout the procedure and is consistent between procedures.

A.3.3 Vocabulary Guidelints for voca v-1rcy usage are as followa:

1. Use short words and words that are common in ordinary conversation.

Page 112 of 378 F

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4.3 Style (Continued)

2. Use nomenclature and idioms that the operatar is trained to use and which are standard in the nuclear power industry.

3. Use concrete and specific words that describe precisely what the operator is to do or observe.

4. Use words and meanings consistently threughout the procedures.

5. Avoid using adverbs that are difficult to define in a precise ranner (e.g. frequently, slowly).

Definitions of action verbs to be used and those to be avoided are provided in Attachment 1.

4.3.4 Abb eviations and Acronyms Abbreviations and acronyms should be those reaaily familiar to the operators so there is no need to consult a glossary in order to identify them.

Abbreviations and acronyms used should conform to the approved Abbreviation & Acronym list provided in Attachment 2.

The use of abbreviations and acronyms should be consistent throughout the E0Is.

4.3.5 Component Identification ,

Component identification codes should correspond to those designated on the control panels so that the operator can readily identify the proper component.

Information on the location of equipment, controls, and displays that are infrequently used, are in out-of-the-way places, or are otherwise difficult to find should be provided. Consider operator experience, the tasks, and the equipment involved to determine whether location information would aid the operator in the efficient performance of the procedure.

4.3.6 Numeric Values and Units All numeric values shall be expressed using arabic numerals.

Numeric values should be written in a style familiar to the operator.

Page 113 of 378

4.3 Style (Continued)

Values of parameters should be presented in a form which corresponds to that on available displays and instrumentation.

The precision of a parameter value should not exceed that which the operator may obtain from reading the instrument or display.

Setpoint values may exceed the precision available on instruments or displays if the setpoint denotes an alarm value or the initiation of an automatic action.

Units of measure should directly relate to those uc.ed on instruments and displays without the need for conversion or manipulation (i.e. feet to inches,' psia to psig, etc.).

Tolerances (where necessary) should be used to bound numeric values and to avoid approximations. The units in which tolerances are expressed should be the same as the units on the display or instrument to which they refer.

4.3.7 Formulas and Calculations The use of formulas and calculations should be minimized. Where possible, use tables or graphs in lieu of calculations. When calculations are required, they should be as simple as possible and adequate space shall be provided for performing the calculation.

4.3.8 Conditional Statements Conditional statements or logic sequences will be used in the E0Is to describe a set of conditions and/or a sequence of actions. Conditional statements should be constructed such that they are logically correct, unambiguous, and complete.

Conditional statements shall be written so that the description of the condition appears first, followed by the action instruction.

To assure the logic approach for the E0Is is consistent, the following guidelines should be used:

1. The logic terms AHQ, QB, II, IHEE, and EHER should be used to construct logic sequences.

2. When action steps are contingent upon a certain condition or set of conditions, the step should begin with the words IE or EHEH followed by a description of the condition (s) and a description of the action to be taken. Examples:

a. II RX water level CAtm0T be determined, THEH enter C2 (EMERGENCY RX DEPRESSURIZATION)

Page 114 of 378 , , , ,

b. EHEH Rx pressure is decreasing, enter LEVEL CONTROL at Step RC/L.

HQIE: The word CAtm0T in the above example is emphasized to highlight the nature of the condition and should not be confused with logic terms.

3. Conditional statements beginning with the logic terms II should always have the word IHEH preceding the action instruction.

4. The term HHEH implies that the operator should continue to test for the condition, and follow the action instruction when it is met.

5. The terms &HD and QR should be used when combinations of conditions are required. The use of &ED and QR should be minimized in action instructions and avoided within the same steps.

6. If multiple uses of logic terms are required to describe a condition or action, a logic diagram should be used rather than a conditional statement.

4.4 Content 4.4.1 Action Steps Action steps should deal with only one idea where possible.

When other actions are to be performed concurrently, the concurrent steps should be explicitly indicated. The number of concurrent steps should not exceed the capability of the control room staff. In addition, the number of procedures being executed concurrently should not exceed the capability of the controi room staff to manage.

4.4.1.1 Sequencing Tasks and action steps should be sequenced according to technical necessity.

Physical layout and organization of the control room should be considered when sequencing tasks and actions, but technical necessity should remain the overriding consideration.

The sequence of action steps should closely follow the outline and bases of the BFN-PSTG.

Action steps shall be performed in the sequence presented unless otherwise stated.

Page 115 of 378

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L' 4.4 Content (Continued)'

4.4.1[2 Verification  !

c Proper sequencing, operator checkoffs, and presenting ,

alternative steps or sequence of steps are methods which should l be used in combination to provide a means for verifying that:

1. An action,has resulted in a positive indication that the equipment has or has not responded to a command.

2. An operator has correctly Jerformed an action or has carried out a series of steps.

3. The objective of & given sequence has been accomplished.

4.4.1.3 Referencing Be specific when referencing another procedure or section of a procedure.

If a sequence of actions is covered completely by another existing procedure and if the original procedure is to be <

re-entered, reference the procedure.

If this information to be referenced can be included in a section of the E0I without greatly increasing its length, a reference should not be used.

Minimize references as much as possible.

4.4.2 Cautions and Notes .

Cautions will be used to attract attention to essential or critical information that addresses conditions, practices, or procedures which must be observed to avoid personal injury, loss of life, a long-term heal *.h hazard, or damage to equipment. ,

Notes will be used to present important supplemental information to 4 aid in job performance and operator training, and facilitate decision making.  ;

Neither notas nor cautions should contain action steps, if at all possible.

Cautions and notes will be written to preclude confusion as to which step or evolution they refer.

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Page 116 of 378 9

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4.4.3 Charts, Tables and Diagrams The values used in charts and tables must correspond to the values the operator will obtain from plant instrumentation and to the written instructions in the procedure.

Charts will be prepared in a size such that the general information is conveyed to the operator.

Logie diagrams will be used only for path direction in the procedure.

4.5 Tvoinn Instructions Margins shall be as follows:

1. The binding margin (the margin on the side of the page which is to be bound) will be no less than one inch to assure that no information is obscured due to the binding of the procedure.

2. All other margine will be no less than 1/2 inch.

The identifying information (See Section 4.2.1) will be no less than 3/8 inch from the top of the page.

Each instructional step and sub-step will be single _ spaced. Double spacing will be used where possible to separate the following:

1. Section headings from instructional steps.

2. Instructional steps from substeps.

3. Substeps.

• 4 Cautions and notes from instructional steps or substeps.

5. Cautions from each other when they appear successively.

6. Notes from each other when they appear successively.

7. Notes and cautions from each other.

Page 117 of 378 , ...

5.0 RESPONSIBILITIES 5.1 Ooerations Suoerintendena.

The Operations Superintendent shall assure that the writers of E0Is follow the conventions presented in this guide.

5.2 Writet The writer shall be responsible for preparing E0Is in accordance with the conventions presented in this guide.

6.0 DOCUMENTATION None 7.0 ILLUSTRATIONS / ATTACHMENTS Attachment 1, Action Verbs Attachment 2, Abbreviations and Acronyms 4

1 i

Page 118 of 378

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ATTACHMENT - 1 ACTION VERBS VIER DEFINITION ACTUATE To put into action or motion; commonly used to refer to automated, multifaceted operations. Use start, move, turn on, or switch on when possible rather than actuate.

ADD To increr7e in size or quantity, such as: "Add oil until the level is at the fill mark".

ADJUST To regulate or bring to a more satisfactory state, such as:

"Adjust.... tank pressure to 100 psig." ,

ALIGN To arrange components into a desired configuration, such as:

"Align the valves."

ALTERNATE To swap an out-of-service component and an in-service component such that the out-of-service component is placed in-service and the original in-service component is placed out-of-service.

ASSURE To observe an expected condition or characteristic without being specific as to the method.

BLOCK .To inhibit an automatic actuation, such as: "Block the PIR relay."

BYPASS To circumvent a piping system component or a logic system function, such as: "Bypass the .... interlocks".

CALCULATE To determine the worth or value of. This action should use detailed steps.

CHARGE To furnish or fill to capacity, such as: "Charge the accumulator".

CHECK To perform a comparison without, roanging the 6catus, such as:

"Check lube oil level between 1/2 and 3/4 full in local sight glass LG-4176."

CLOSE To change the physical position of a mechanical or electrical device to prevent physical access or flow, or permit passage of electrical current, such as: "Close.... valve.'

COMMINCE To begin or start.

Page 119 of 378 . ...

4 m

I ACTION VERBS YERA DEFINITION COMPARE To examine or observe to determine resemblances or differences, such as: "Compare incoming and running voltages on....."

CONFIRM To support or establish the certainty or validity of.

CONNECT To join or fasten, such as: "Connect the hose."

CONTINUE To go on with a particular action, such as: "Continue with the activity."

CONTROL To manually operate equipment as necessary to satisfy guideline requirements, such as: "Control..... tank level between....."

DECREASE Avoid use because of oral communication problems. Use, throttle, reduce, lower, when possible.

DEPRESS To press down, such as: "De7ress the push button."

DEPRESSURIZE To release from pressure.

DETERMINE To calculate, find out, decide, or evaluate, a tch as ,

"Determine the concentration."

DIRECT To cause to move in or follow a particular course, such as:

"Direct the water to the .... drain".

DISADLE To prevent the operation of an otherwise automatic function, such as: "Disable the ADS auto blowdown function".

DISCONNECT To separate or detach, such as: "Disconnect the hose."

DRAIN To draw or flow off a liquid, such as: "Drain the oil from the motor."

ENERGIZE To supply electrical energy to a component; commonly used to describe an electrical bus or other dedicated electrical path, such as: "Energize the bus."

ENSURE To observe an expected condition or characteristic without being specific as to the method. Check or verify is a recommended replacement.

l l

l l

Page 120 of 378 4

m._ ..--e _3 ,_. - _ . . _ _ _ , _ ~ . - , - , _ - _ _ _ _ _ . , _ _ .,, _.

, ___,,__.c

.~ ,. , . . - ,

ACTION VERBS EERS DEFINITION ENTER To come or to go into, such as: "Enter the procedure".

EVALUATE To examine and decide with respect to some criteria. To the extent p:.asible, the decision criteria should be provided within the instructions.

EXECUTE To carry out or put into effect, such as: "Execute .... -

procedure".

EXIT The act of getting out of or getting away from.- .

FILL To occupy with an object, such as: "Fill the tank to..."

. FLOOD To fill with an abundance or an excess, such as: "Flood the Rx";

FLUSH To make clean by brief, rapid, gush of fluid, such as: " Flush RHk discharge piping."

HOLD To maintain in a position, such as: "Hold the push button in ihn Trip position until...."

INCREASE Avoid use because of .ral communication problems. Use raise when possible.

INDUCE To bring about the occurrence of, or cause.

INITIATE To begin an activity or function, such as: "Initiate the Radiological Emergency Plan."

INJECT To introduce & fluid into, such as: "Inject water into the Rx using the following systems ".

INSERT To put or set into, between, or among.

INSTALL To establish in an indicated place, such as: "Install the fuse."

ISOLATE To set apart from. To close ene or more valves in a system for the purpose of separating or setting apart a complete system or a portion of the system.

Page 121 of 378

=

ACTION VERBS ygg3 ,

DEFINITION LAND To replace a lifted lead back in its original position.

LIrr To remove or pick up, such as: "Lift the leads."

LIMIT To restrict or set bounds, such as: "Limit the time in high radiation areas."

LOWER To let down, diminish, move down, or pull down, such as:

"Lower to 28 Vdc by turning. . . . . counterclockwise."

MAINTAIN To control, hold, or keep in an existing state.

MONITOR Similar to "check," except implies a continuous or frequently repeated activity.

NOTIFY To give notice to, or inform.

OBTAIN To succeed in gaining possession of; procure or acquire.

OBSERVE The same as check.

OPEN To change the physical position of a mechanical or electrical device to allow flow through a valve and block electrical current flow through a breaker.

OPERATE To turn on or turn off as necessary to achieve the stated objective or function.

PLACE To move a control to a stated position, such as: "Place the Main Power Switch to STANDBY."

l PREVENT Take action as necessary to preclude the stated action, occurrence, etc.

PROCEED To go forward or onward to a specified location.

PROTECT To keep from harm or damage.

PUSH Move equipment or actuate equipment away from the motivating force location.

Page 122 of 378 9

ACTION VERBS YKRH DEFINITION RACK IN To place an electrical circuit breaker in place by physically connecting it to its associated power source.

RACK OUT To disconnect an electrical circuit breaker by physically removing it from its associated power source.

RAISF. To increase in amount, such as: "Raise the tank level."

REDUCE To cause a parameter to decrease in value.

REFILL To fill ar,ain; a second or subsequent filling.

REMOVE To transfer or move, such as: "Remove the fuse."

REPLACE To put back in a former position or place.

REPRESSURIZE To begin to increase pressure again following a previous reduction it pressure.

RESET To removs an active output signal from a retentive logic device; commcaly used in reference to protection / safeguards logics in which the actuating signal is "sealed in."

RESTART To start again, to begin ope?ating again.

RESTORE To bring a specified paramet.!r or component back within specified limits.

SECURE To fasten, make safe, or tie.

SELECT To choose from among several;_ pick out, such as: "Select control rod ...."

SEPARATE To set or keep apart; or space apart; disunite.

SET To phytically adjust an adjustable feature to a specified value, such as: "Set diesel speed to... rpm."

SHALL Defines or states a mandatory requirement.

SHOULD To denote a reccmmendation.

Page 123 of 378 . . . .

ACTION VERBS yegg DEFINITION SHUT DOWN To stop operating equipment and place in standby. When shutdown appears as one word, it la used as a noun.

STABILIZE To bring specified parameter under control with any fluctuations controlled.

START To originate motion of an electrical or mechanical device, either directly or by remote control, such as: "Start... pump."

STOP To shut down equipment, su..h as: "Stop... pump."

SUBTRACT To take away or deduct.

THROTTLE To operate a valve in an intermediate position to obtain a certain flow rate, such as: "Throttle open... val,ve."

TRIP To manually activate or deactivate a semiabtomatic feature, such as: "Trip breaker..."

TROUBLESHOOT Investigate for the purpose of locating and eliminating sources of problens.

TURN To cause to move at an angle or circle, such as: "Turn the shaft clockwise."

USE To bring or put into service; employ.

VENT To permit a gas or liquid confined under pressure to escape, such as: "Vent... pump."

VERITY Observe that an expected characteristic or condition exists.

If necessary, take action to obtain the expected characteristic or condition, or provide a notification for obtaining the' expected characteristic or condition.

l WITHDRAW To move from a position, such as: "Withdraw the control rod."

l l

Page 124 of 378

t ATTACHM2NT - 2 ABBREVIATIONS AND ACRONYMS 1135 ABBREVIATION /ACR M Automatic AUTO Automatic Depressurization System ADSJ Auxiliary AUX Auxiliary 011 Pump AOP Average Power Range Monitor APRM Booster BSTR Condensate CNDS -

Condensate Storage Tank CST Containment CirrMT Contingency C Control Rod Drive CRD Core Spray CS Curie Ci Degrees DEG Differential DIFF Differential Pressure DP Discharge DISCH Drywell DW Drywell Temperature Control DW/T Elevation EL Emergency Core Cooling System ECCS Emergency Operating Instruction E0I Page 125 of 378 , ,

IE33 ABBREVIATION / ACRONYM Exhaust '

EXH ,

Fahrenheit F Flow Control Valve FCV a

Foot or Feet FT Gallons Per Minute GPM General Operatins-Instruction GOI Heatins, Ventilation, and Air Conditioning HVAC High Pressure Coolant Injection HPCI Hour HR

, Hydraulic Control Unit HCU Inch or Inches IN Initiation INIT Injection INJ Level LVL Level Indicator LI 4

Local Power Range Monitor LPRM Loss of Coolant Accident LOCA Low Pressure Coolant Injection LPCI Main Steam Isolation Valve MSIV Maximum MAX Millirem MR Minute MIN Net Positive Suction Head NPSH Northeast NE Northwest NW Page 126 of 378 e

m_

I f i i I135 ABBREVIATION / ACRONYM Pounds Per Square Inch Absolute PSIA l Pounds Per Square Inch Cauge PSIG j i

. Pressure Con.rol Valve

. PCV ,

t Pressure Indicator PI }

t f

Pressure Suppression Chamber PSC t

Pressure Switch PS  !

i Primary Containment PC i

Primary Containment Isolation Signal PCIS Primary Containment Pressure Control P ;/P i Procedure PROC Reactor RX ,

Reactor Core Isolation Coeling RCIC Reactor Feedvater Pump Turbine RFPT Reactor Level Control RC/L , ,

Reactor Power Control RC/Q

. I Reactor Pressure Control RC/P Reactor Pressure Vessel RPV ~i Reactor Protection System RPS l l

Reactor Water Cleanup RWCU l

Recirculation RECIRC f i

Residual Heat Removal RHR (

l Residual Heat Removal Service Wator RHRSW Revolutions Per Minute RPM  ;

i Rod Sequence Control System RSCS  !

t Rod Worth Minimizer RWM

[

i i

i i t

{

Page 127 of 378

IM A9BREVIATION/ ACRONYM Safety / Relief Valve SRV Scram Discharge Volume SDV Secondary Containment Level Contriol SC/L Secondary Containment Radiation Contrcl SC/R Secondary Containment Temperature Centrol SC/T Senior Reactor Operator SRO Source Range Monitor SRM Southeast SE Southwest SW Standby STBY Standby Gas Treatment System SGTS Standby Liquid Control SLC Steam Jet Air Ejector SJAE Suppression SUPPR Suppression Pool Temperature Cont.rol SP/T Suppression Pool Water Level Control SP/L Temperature TEMP Temperature Indicator TI y e Temperature Recorder TR Traversing Incore Probe TIP Turbine TURB Valve VLV Page 128 of 378 , ,

1 l

I I

i l

EMERGENCY OPERATING INSTRUCTION DEVIATIONS CROSS REFERENCE DOCUMENT Page 129 of 378

TABLE OF CONTENTS Section Page Introduction . . . . . . . . . . . . . . . . . . . . . . . . . 131 Cautions . . . . . . . . . . . . . . . . . . . . . . . . . . . 132 Rx Control Guideline . . . . . . . . . . . . .. . . . . . . . . 161 RC/L . . . . . . . . . . . . . . . . . . . . . . . . . . 163 RC/P . . . . . . . . . . . . . . .. . . . . . . . . . . 177 RC/Q . . . . . . . . . . . . . . . . . . . . . . . . . 189 Primary Containment Control Guideline . . . . . . . . . . . . .205 SP/T . . . . . . . . . . . . . . . . . . . . . . . . . . 208 DW/T . . . . . . . . . . . . . . . . . . . . . . . . . . 213 PC/P . . . . . . . . . . . . . . . . . . . . . . . . . . 220 SP/L . . . . . . . . . . . . . . . . . . . . . . . . . . 232 Secondary Containment Control Guideline . . . . . . . . . . . .248 SC/T . . . . . . . . . . . . . . . . . . . . . . . . . . 250 SC/R . . . . . . . . . . . . . . . . . . . . . . . . . . 260 SC/L , . . . . . . . . . . . . . . . . . . . . . . . . . ?65 Radioactivicy Release Control Guideline . . . . . . . . . . . .278 Contingencies . . . . . . . . . . . . . . . . . . . . . . . . .282 1 - Alternate Level Control . . . . . . . . . . . . . . . 283 2 - Emergency Rx Depressurization . . . . . . . . . . . . 298 3 - Steam Cooling . . . . . . . . . . . . . . . . . . . . 305 4 - Rx Flooding . . . . . . . . . . . . . . . . . . . . . 310

$ - Level / Power Control . . . , . . . . . . . . . . . . . 334 7 - Core Cooling Without Level Restoration . . . . . . . .355 TABLES .

Operating Values of Secondary Containment Parameters . . . . . 270 FIGURES A - Rx Saturation Temperature . . . . . . . . . . . . . . 362 B - RHR NPSH Limit. . . . . . . . . . . . . . . . . . . . 363 C - Dryvell Spray Initiation Limit . . . . . . . . . . . .364 D - Pressure Suppression Pressure Limit . . . . . . . . . 365 E - Heat Capacity Level Limit . . . . . . . . . . . . . . 366 F - Heat Capacity Temperature Limit . . . . . . . . . . . 367 G - Suppression Pool Load Limit . . . . . . . . . . . . . 368 H - CS NPSH Limit . . . . . . . . . . . . . . . . . . . . 369 Page 130 of 378

- y- -,,- ,y- .----. , , - - . - ,

l PSTG STEP EPG STEP No corresponding caution. Caution #1 Monitor RPV water level and pressurel and primary containment temperature and pressure from multiple indications.

O D JUSTIFICATION OF DIFFERENCE This caution has been removed from the PSTGs and placed in Plant Managers Instruction, PMI-12.12, "Conduct of Operations" in order to avoid cluttering up the PSTGs. It is not necessary to incorporate this caution in the PSTGs because all operators are trained to monitor parameters from multiple indications, where possible.

Page 134 of 378 , , , ,

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

PSTG STEE EPG STEP No corresponding caution. Caution #3 If a cafety function initiates auto-matica11y, assume a true initiating event has occurred unless otherwise confirmed by at least two independent indications.

JUSTIFICATION OF DIFFERENCE This caution has been removed from the PSTGs and placed in Plant Managers Instruction, PMI-12.12, "Conduct of Operations" in order to avoid cluttering up the PSTGs. It is not necessary to incorporate this caution in the PSTGs because all operators are trained to assume that safety function automatic initiations are true unless otherwise indicated by multiple indications, i

Page 135 of 378 - ...

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, - - .-= .._- . .. _.. ..

PSTG STEP EPG STEP No' corresponding caution. Caution #4 Whenever RHR is in the LPCI mode, inject through the heat exchangers as soon as possible.

JUSTIFICATION OF DIFFERENCE This caution actually specifies an action. The action is incorporated in the PSTGs in the s.teps specifying LPC1 operation (steps RC/L, Cl-1, C4-1.3, C5-2, C5-2.2.3). However, since BFN does not have bypass lines around the RHR heat exchangers the action specifies starting the applicable RHRSW pumps as soon as possible. The intent is the same in both c.ases.

l Page 136 of 378 e

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_ .m._ y _. r --_ _ _ __--

PSTG STEP EPG STEP No correspondi'gn caution. ,

Caution #5 Suppression pool temperature is deter-mined by (procedure for determining bulk suppression pool water temper-ature]. Drywell temperature is deter-mined by (procedure for determining drywell atmosphere average temperature]

Containment temperature is determined by (procedure for determining MARK III containment atmosphere average temperature).

JUSTIFICATION OF DIFFERENCE The bulk suppression pool temperature is available in the control room as redundant, independent indications, thus no caution is necessary.

Drywell average air temperature can be calculated by using TI-82.

Containment temperature indication applies to Mark III containment types only and is therefore not applicable to Browns Ferry.

Page 137 of 378 e . . .

t

PSTG STEP CAUTION fil Use Rx water level instruments to determine Rx water level only when all of the following conditions are satisfied:

1. The temperatures near the instrument reference leg vertical runs are below the Rx Saturation Temperature (See Figure A).

2. For each of the instruments in the following table, the temperatures near the instrument reference leg vertical runs are below the Maximum Run Temperature or the instrument reads above.

the minimum indicated level.

Minimum Maximum Temperature Indicated Run Instrument Point Level Temperature Post Accident Floeding Range (-100 to +200 in.)

LI-3-52 TI-80-34-6 -100 300 LI-3-62 Average of TI-80-34-7 & 8

• Emergency System Range (-155 to + 60 in.)

LI-3-46A(units 1, 3) TI-80-34-6 -155 in. 180 deg F LI-3-58A(unit _2) -150 in. 220 deg F LI-3-46B(units 1, 3) Average of -140 in. 300 deg F TI-80-34-7&8 LI-3-58B(unit 2)

Normal Control Ranze - - (0 to + 60 in.)

LI-3-53 & 206 TI-80-34-6 0 300 LI-3-60 Average of TI-80-34-7 & 8

• Shutdown Vessel Flooding Range (0 to + 400 in.)

LI-3-55 TR-80-1-10(units 1) 10 in. 140 deg F TR-80-1-9(units 2,3) 15 in. 180 deg F 20 in. 210 deg F

• - 25 in. 240 deg F 30 in. 270 deg F 35 in. 300 deg F

• Indicates differences between units.

Page 138 of 378 ..

EPG STEP CAUTION #6

1. detever (temperature near the instrument reference leg vertical runs) exceeds the timperature in-the table and the instrument reeds below the indicated level in the table, the actual RPV water level may be anywhere below the elevation of the lower it.strument tap.

2. For each of the instruments in the following table, the temperatures Indicated Temperature [*] Level Instrument any 617 in. Shutdown Range Level ( 500 to 900 in.)

107'F -107 in. Wide Range Level (-150 to +60 in.)

310*F 19 in. Narrow Range Level ( 0 to +60 in.)

545'F 168 in. Fuel Zone Level ( 200 to 500 in.)

(* List in order of increasing temperature.]

J_USTIFICATION OF DIFFERENCE PSTG caution #1 contains guidance on the conditions under which Rx watcy level indication may be avaflable. The caution is broken up into two parts, each dealing with a different phenomena that can affect Rx water level indicatien. The first part of caution #1 was written to replace the material contained la EPG step DW/T-2. This step deals with primary containment temperatures above Rx sattration temperature and corresponding loss of Rx water level indication. This material was deleted from the DW/T portion of the PSTG because drywell temperatures above the Rx Saturation Temperature are no longer an automatic condition for Rx flooding. The only condition for flooding in the PSTG is complete loss of level indication.

Usirg that logic, this material was relocated in PSTG caution #1 to indicate to the operators that water level indication may be unreliable under that condition. The second part of PSTG caution #1 corresponds to EPG caution #6. Although the instruction and wording of the two is not identical, the intent is the same. Both deal with loss of portion of the indicating range of the water level instrumentation due to increasing drywell temperature. These changes were thought by the owners group subcommittee to be improvements to the EPGs and were incorporated in a later revision of the EPGs.

Page 139 of 378

PSTG STEP EPG STEP Caution #2 Caution #7 Level instruments LI-3-46A, B [ Heated referenced leg instrument]

(units 1, 3) and LI-3-58A, B indicated levels are not reliable (unit 2) are'n-t reliable during during rapid RPV depressurization rapid Rx depressurization below below 500 psig. For these conditions, 500 psig. For these conditions, utilize [ cold reference leg instru-use other water level instruments ments] to monitor RPV water level.

to monitor Rx water level.

l -

l l JUSTIFICATION OF P.IFFERENCE l

l The PSTG cautions are renumbered due to fewer cautions. The only heated reference leg instruments at Browns Ferry are the Emergency Systems Range instruments located on panel 9-5 whose instrument numbers are listed in the caution.

l l

Page 140 of 378

PSTG STEP '

EPG STEP Caution #8 ,

No corresponding caution. -Observe NPSH requirements for pumps taking suction from the suppression pool.

JUSTIFICATION OF DIFFERENCE The EPG caution implied that action should be taken to reduce flow in order to stay within the NPSH limit. For the PSTGs, the direction to maintain flow below the NPSH limit is given in the form of an action step and is applied in the PSTGs at those points where RHR and Core Spray use is directed and RPSH is a concern (steps RC/L-2 and C5-2).

s Page 141 of 378 O

PSTG STEP EPG STEP Caution #9 No corresponding caution. If. signals of high suppression pool water level (12 ft. 7 in. (high level suction interlock)] or low condensate storage tank water level (0 in. (low level suction interlock)] occur, confirm automatic transfer of or manually transfer HPCI, HPCS, and RCIC suction from the condensate storage tank to the suppression pool.

't JUSTIFICATION OF DIFFERENCE This caution is omitted from the PSTG. The moot likely events in which HPCI or RCIC (Browns Ferry does not have a HPCS) would still be in use with the suppression pool level high are an ATVS or a station blackout. In either event, with suppression pool level high, suppression pool temperature would also be high. With suppression pool temperature high, HPCI and RCIC system operation is threatened due to loss of NPSH and possi* ale equipment failure due to high lube oil temperatures. During a station blackout, operation of the suction valves is not desirable since these operations would more quickly deplete the station batterie's. It is also believed that supplying additional water to the CST would be relatively simple.

Page 142 of 378 , ,

PSTG STEP EPG STEP Caut' ion #10 No corresponding caution. Do not secure or place an ECCS in MANUAL mode unless, by at least two independent indications, (1) misopera-tion in AUTOMATIC mode is confirmed, or (2) adequate core cooling is assured.

If an ECCS is placed in MA!UAL mode, it will not initiate automatically. Make frequent checks of the initiating or controlling parameter. When manual operation is no longer required, re-store the system to AUTOMATIC / STANDBY mode if possible.

JUSTIFICATION OF DIFFERENCE This EPG caution is not contained in the PSTG because it provides extraneous information. The opetttors are trained on how to operate ECCS and the material in thiu caution contains no additional, useful information.

Page 143 of 378 ,, , , ,

PSTG STEP EPG STEP No corresponding caution. Caution #11 If a high drywell pressure ECCS initia-tion signal [2.0 psig (drywell pressure which initiates ECCS)] occurs or exists while depressurizing, prevent injection from those LPCS and LPCI pumps not required to assure. adequate core cooling prior to reaching their maximum injection pressures. When the high drywell pressure ECCS initiation signal clears, restore LPCS and LPCI to AUTOMATIC / STANDBY mode.

JUSTIFICATION OF DITFERENCE This caution was omitted because it contains an action step. This guidance has been placed in the text of the PSTG where pressure control actions may direct the operator to reduce Rx pressure below CS pump shutoff head (guidance contained in RC/P, C2).

Page 144 of 378 , ...

PSTG STEP EPG STEP Caution #3 Caution #12

' Operating HPCI turbine below 2400 rpm Do not throttle HPCI or RCIC systems (minimum turbine speed limit per below (2200 rpm (minimum turbine speed system test experience) or RCIC limit per turbine vendor manual)].

turbine below 2100 rpm (minimum turbine speed limit per turbine vendor manual) may result in unstable system operation and equipment damage.

JUSTIFICATION OF DIFFERENCE EPG caution 12 is an action statement. This has been reworded to provide more detail to the operator and to make this statement passive. Also, the basis for the minimum turbine speed for HPCI is different in the PSTGs from that identified in the EPGs. The minimum HPCI turbine speed per the vendor manual was 2150 RPM, however, preoperational tests of HPCI showed that operation below 2400 RPM should be avoided due to excessive check valve chattering and control valve steam cutting.

Page 145 of 378 . ..

PSTG STEP EPG STEP Caution #13 No corresponding caution. Cooldown rates above (100*F/hr (RPV cooldown rate LCO)] may be required to accomplish this step.

JUSTIFICATION OF DIFFERENCE The operators are trained that cooldown rates above 100*F/hr may be required to accomplish certain steps in the PSTGs. In an emergency, it is sometimes necessary to depressurize at such a rate that the cooldown rate LCO is exceeded. In these cases, the required depressurization action takes precedence over the concerns associated with exceeding the cooldown rate. Since there are numerous occurrences in the PSTGs where the cooldown rate is likel.y to be exceeded by the required action and since the operators are aware of these requirements, we felt there was no need to include this caution in the PSTGs.

Page 146 of 3/8 . ...

i PSTG STEP EPG STEP Caution #14 No corresponding caution. Do not depressurize the RPV below (100 psig (HPCI or RCIC low pressure isolation setpoint, whichever is higher)] unless motor driven pumps sufficient to maintain RPV water level are running and available for in-jection.

JUSTIFICATION OF DIFFERENCE This caution is deleted since in all likelihood it cannot be performed. The purpose of this caution is to' prevent depressurizing the Rx below the isolation setpoint of HPCI and RCIC when there are no motor driven pumps available for injection. The caution is actually a step specifyiing action, but as discussed below, it is an action which cannot be carried out.

t There are two conditions involved here; both of which we are attempting to meet by j virtue of this caution. These conditions are: 1) maintenance of adequate core

cooling and 2) maintenance of Rx pressure above the low pressure HPCI/RCIC l isolation setpoint.

Page 147 of 378 , . . .

I

At the August 1985 meeting of the Emergency Procedures subcommittee, General Electric presented data related to these concerns. Information involving HPCI indicated that even with HPCI at its lowest allowable operating speed, HPCI could provide adequate core cooling (ACC) but the steam demand would be so great that the vessel could not remain pressurized above the isolation setpoint. Data on RCIC indicated that with RCIC operating at its lowest speed, pressure could probably be maintained above the isolation setpoint but ACC would not be assured.

What we are left with is one system (HPCI) which can assure ACC but by itself will depressurize the Rx below the isolation setpoint, and one system (RCIC) which may or may not depressurize the Rx but the use of which will not guarantee ACC.

Therefore, neither system is capable of providing ACC and at the same time controlling Rx pressure above the isolation setpoint. Caution #14 is, therefore, unnecessary and has been deleted.

l Page 148 of 378 . ,,,

l l

l PSTG STEP EPG STEP Caution #15 No corresponding caution. Open SRVs in the following sequence

, if possible: [SRV opening sequence).

JUSTIFICATION OF DIFFERENCE This is an action statement rather.than a caution and is incorporated as an action step where operation of the SRVs is directed (step RC/P-2).

Page 149 of 378 , . . .

l PSTG STEP EPG STEP Caution #16 No corresponding caution. Bypassing low RPV water level [ventila-tion system and] MSIV isolation inter-locks may be required to accomplish this step.

i-JUSTIFICATION OF DIFFERENCE This ca ction is incorporated in the PSTG as part of the action statement that directs the operator to re-o'sn p MSIVs (conditional statement prior to PC/P-2).

Page 150 of 378 .c . . .

l PSTG STEP EPG STEP

. Caution #17 No corresponding caution. Cooldown rates above (100*F/hr (RPV cooldown rate LCO)] may be required to conserve RPV vater inventory, protect primary containment' integrity, or limit radioactive release to the environment.

JUSTIFICATION OF DIFFERENCE The operators are trained that co'oldown rates above 1000F/hr may be required to accomplish certain steps in'the PSTGs. In an emergency, it is sometimes'necessary to depressurize at such a rate that the cooldown rate LCO is exceeded. In these cases, the required depressurization action takes precedence over the concerns associated with exceeding the cooldown rate. Since there are numerous occurrences in the PSTGs where the cooldown rate is likely to be exceeded by the required action and since the operators are aware of these requirements, we felt there was no need to include this caution in the PSTGs.

Page 151 of 378 , ,,

r ESTG STEP EPG STEP Caution #18 No corresponding caution. If continuous LPCI operation is required to assure adequate core cooling, do not divert all RHR pumps from LPCI mode.

l l

e r

! JUSTIFICATION OF DIFFERENCE t

This caution provides direction for an action and is incorporated in the applicable steps in the PSTGs'(steps RC/P-4, SP/T-1, DW/T 2.3, PC/P-2, PC/P-3, SP/L-3.2.1).

Page 152 of 373 , , , ,

I

PSTG STEP EPG STEP Caution #19 No corresponding caution. Confirm automatic trip or manually trip SLC pumps at [0% (low level trip)] in the SLC tank. ]

JUSTIFICATION OF DIFFERENCE This caution directs action to be'taken and is therefore incorporated in the text

! of the PSTGs. This guidance'is in the form of a conditional statement placed l

prior to step in RC/Q-4.3.

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I Page 153 of 378 . ...

I

. PSTG STEP EPG STEP Caution #20 No corresponding cr cion. Defeating RSCS interlocks may be required to accomplish this step.

JUSTIFICATION OF DIFFERENCE This caution is incorporated in the PSTGs as part of step RC/Q-5.5.3 that directs manual rod insertion.

Page 154 of 378 - .._

-1 1

. PSTG STEP EPG STEP Caution #4 Caution #21 .

Elevated suppression chamber pressure Elevated suppression chamber pressure may trip the RCIC turbine on high may trip the RCIC turbine on high 4 exhaust pressure. exhaust pressure.

l 4

1-1 JUSTIFICATION OF DIFFERENCE The PSTG caution is renumbered,due to fewer cautions.

Page 155 of 378 ,, ,,,

E PSTG STEP EPG STEP Caution #22 No corresponding caution. Defeating isolation interlocks may be.

required to accomplish this step..

JUSTIFICATION OF DIFFERENCE This caution is incorporated .in tihe PSTGs as part of steps PC/P-5 and C2-1.3 requiring the specific interl'ocks to be bypassed, t

A 1

Page 156 of 378 ,,,

c e

-r ,, ,=- -g~ ~ r-,m.--,,r-. . m, , - - , -,ww-o, n,--,-yy . - , - g--g --.w - yn.- - w +-, - ,, -

w ---n-- -~ rw--,, - - ,--g - + w- ~ -

PSTG STEP EPG STEP Caution #23 No corresponding caution. Do not initiate drywell sprays if sup-pression pool water level is above (17 ft. 2 in. (elevation of bottom of Mark I internal suppression chamber to drywell vacuum breakers less vacuum breaker opening pressure in feet of water)].

t JUSTIFICATION OF DIFFERENCE This caution is incorporated in the PSTGs as part of step SP/L-3.2.

Page 157 of 378 , ...

PSTG STEP EPG STEP Caution #24 No corresponding caution. Bypassing high drywell pressure and low RPV water level secondary containment HVAC isolation interic-sa may be required to accomplish this step.

i J

JUST7FICATION OF DIFFERJNCE This caution has been incorporated as part of the conditional statement at the beginning of the Secondary Containment Control Guideline.

Page 158 of 378 . , , ,

. l

PSTG STEP , EPG STEP Caution OS Caution #25 A rapid increase in injection into A rapid increase in injection into the the Rx may induce a large power RPV may induce a large power excursion excursion and result in substantial and result in substantial core damage, core damage.

4 JUSTIFICATION OF DIFFERENCE The PSTG caution is remunbered due to fewer PSTG cautions.

h Page 159 of 378 , , , ,

4.2 Fo rmat (Continued)

3. Substeps shall be numbered by addition of a digit following a decimal point (Ex: RC/L-1.1). Substeps may be indented where necessary for clarity.

4. Following steps will be lettered to assure clarity and to minimize the confusion caused by complicated step numbers.

Step numbering for separate actions is not an absolute requirement if the correct action to take is apparent from indenting or other means.

EXAMPLE: RC/Q-5 Major step RC/Q-5.1 Substep

a. Step

b. Step

c. Step

5. Each action step shall be wholly contained on a single page.

6. Override steps which direct the operator to take an action outside the normal flow of the procedure (Ex: instructions to enter contingencies) or steps containing an unexpected action shall be enclosed in boxes as shown:

II Rx water level CANNOT be determined, IliEI{ enter C2 (EMERGENCY RX DEPRESSURIZATION)

7. In various places throughout the procedure, parentheses are

. used to enclose additional material provided for one of the following reasons:

Provide plant specific action limits, setpoints, and instrument numbers Provide amplifying information where, in the opinion of the writer, necessary Provide references to other sections in the procedure 4.2.4 Caution and Note Statements Caution statements shall be enclosed by asterisks with the word "CAUTION" displayed above as shown:

• CAUTION *

• Elevated torus pressure may trip RCIC on high exhaust pressure.

• i Page 109 of 378 I

PSTG STEP EPG STEP Caution #26 No' corresponding caution. Large reactor power oscillations may be-observed while executing this step.

i .

4 JUSTIFICATION OF DIFFERENCE This caut a is incorporated _in step C5-1 to clarify that the action is to be

, taken regardless of large reactor power oscillations.

Page 160 of 378 .._

_-y --- --- -, -,..,-.7,,r.,yv._ _ ,__,_._,..~,y,mn,.my-.____m.%-.yg%3w w y- -y,y9

RX C0!rIROL GUIDELI!TE 9

I I

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Page 161 of 378 . . . .

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1.

PSTG STEP EPG STEP The entry co'nditions for this guide- Entry Conditions line are any of the following:

RPV water level below [+12 in. (low Rx water level below +11 level scram setpoint))

inches (low level scram setpoint)

• RPV pressure above (1045 psig (high RPV

- Rx pressure above 1043 psig pressure scram setpoint)]

(high Rx pressure scram setpoint) Drywell pressure above (2.0 raig

- Drywell pressure above 2.45 psig (high drywell pressure scrcm (high drywell pressure scram setpoint)]

setpoint) A condition which requires MSIV

- A condition which requires a Rx isolation scram, and Rx power above 3%

• A condition which requires reactor (APRM downscale trip) or cannot scram, and reactor power above (3%

be determined (APRM downscale trip)] or cannot be

- A condition which requires an determined.

MSIV isolation.

JJOTIFICATION OF DIFFERENCE The BNF plant specific nomi.tal setpoints are substituted in the PSTGs in place of generic representative valtes in the ZPGs as appropriate. The bases remain unchanged, l

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Page 162 of 378 ,, ,,,

x

-< s PSTG STEP EPG STEP RC/L Monitor.and control l#1. #2l RC/L Monitor and control RPV vater level.

Rx water level.

1 i

i i

JUSTIFICATION OF DIFFERENCE Cautions 1 and 2 pertain to conditions in which wate.r level instrumentation may not  ;

be reliable. It is appropri' ate to provide these cautions to the operator at the point he is direc.ted to monitor and control Rx water level. 7 i

L Page 163 of 378 , , , ,

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

PSTG STEP EPG STEP RC/L-1 Initi te each of the following RC/L-1 Confirm initiation of any of which should have been initi- the following:

ated but did not:

Isolation

- PCIS Group 1 Isolation

• ECCS

- FCIS Group 2 Isolation (* Emergency diesel generator)

- PCIS Group 3 Isolation

- PCIS Group 8 Isolation Initiate any of these which

- HPCI should have initiated but

- RCIC did not.

- Core Spray

, LPCI, placing the appli-cable RERSW pump (s) in service as soon as possible JUSTIFICATION OF DIFFERENCE The PSTG step specifies the isolations which actuate .to terminate reactor coolant inventory loss ar.d simplify Rx water level control. The appropriate ECCS systems (plus RCIC) that automatically initiate to provide makeup water are listed. The emergency diesel generator is not included since this only applies to plants which must rely on diesel-supplied electrical power for Rx water level control. If an emergency diesel generator is not always required, its initiation should be verified when the system or systems which will require the diesel generator are lined up and placed in service.

Page 164 of 378 - . . .

PSTG STEP EPG STEP If while executing step RC/L-2: If while executing the following step:

- Any control rod is not inserted Boron injection is required, enter to or beyond position 02 (procedure developed from CONTINGENCY (Maximum Suberitical Banked

• 7].

Withdrawal Position), disable ADS RPV vater level cannot be determined, auto blowdown function and enter RPV FLOODING IS REQUIRED; enter the procedure developed from (procedure developed from Contingency CONTINGENCY 5.

1. 6].

RPV Flooding is required, enter

- Rx water level cannot be deter- (procedure developed from CONTINGENCY mined, enter the procedure #6].

developed from CONTINGENCY 2.

JUSTIFICATION OF DIFFERENCE The condition for transferring level control is changed from a flag indicating several conditions (Boron injection required) to a symptom ('any control rod not inserted to or beyond the Maximum Suberitical Banked Withdrawal Position).

Positive confirmation that the Rx vill remain shutdown under all conditions is best obtained by determining that all rods are inserted beyond the Maximum Subcritical Banked Withdrawal Position. If any possibility exists that the Rx may not always remain shutdown on control rod insertion alone, the actions required for control of Rx vater level differ from those outlined in the Rx Control Guideline. The Rx vater level control actions that are appropriate under this condition are specified in Contingency 5, ' Level / Power Control'.

Disabling ADS if any contr.ol rod is not inserted to or beyond position 02 is done because actions called out in Contingency 5 may require the operator to deliberately lower Rx water level to a level below the automatic initiation setpoint of ADS. Actuation of this system imposes a severe thermal transient on the vessel and complicates efforts to maintain Rx vater level within the ranges specified in Continency 5. Further, rapid and uncontrolled injection of large amounts of cold, unborated water from low pressure injection systems may occur as Rx pressure decreases below the shutoff head of these pumps. Such an occurrence would quickly dilute in-core boron concentration and reduce coolant temperature.

When the Rx is not shutdown, or when the shutdown margin is small, sufficient positive reactivity might be added in this manner to cause a Rx power excursion large enough to severely damage the core. Therefore, ADS initiation is purposely prevented when the operator is directed to Contingency 5, ' Level / Power Control'.

If required, explicit direction to depressurize the Rx is provided in the PSTGs thereby negating any requirement to maintain the automatic initiation capability of ADS.

Page 165 of 378 . ,_

In tho etnditicnni etettment box preceding RC/L-2, ths direction is to enter C2 if flooding is required. This is a more efficient method of directing flooding actions than is c used in the EPGs. Since flooding is performed at low pressure, Emergency Depressurization is required before Rx flooding. The PSTGs therefore, shift procedural control directly to Contingency 2 instead of relying on RC/P to direct the operator to go to C2 if Rx flooding is required.

9 Page 166 of 378 . . . .

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PSTG STEP EPG STEP RC/L-2 Restore and maintain Rx water RC/L-2 Restore and maintain RPV #9 level between +11 in. (low water level betweed (+12 in.

level scram setpoint) and (lov level scram setpoint)] #10

+54 in. (high level trip and (+58 in. (high IcVel .Jdj.,

setpoint) with one or more of trip setpoint))

the following systems: with one or more of the following systems:

• Condensate /feedwater

• CRD

• Condensate /feedwater system

• RCIC with suction (1110 - O psig (RPV pressure from the CST, l#3. #41 range for system operation))

defeating low Rx

• CRD system (1110 - O psis (RPV pressure isolation inter- pressure range for system locks, if necessary, operation))

' HPCI with suction

• RCIC system (1110 - 50 psig from the CST, lill (RPV pressure range for system defeating high operation))

suppression pool water level

• HPCI system (1110 - 100 psig suction transfer logic if (RPV pressure range for system suppression pool temperature operation)]

is greater than 140*F.

• HPCS system (1110 - 0.psig

• CS; control and maintain (RPV pressure range for system pump flow below the CS pump operation)]

NPSH Limit (see Figure H).

• LPCS system (425 - O psig (RPV

' LPCI; control and maintain pressure range for system pump flow below the RER pump operation)]

NPSH Limit (see Fi*gure B).*

• LPCI system (250 - O psig (RPV Place applicable RHRSW pressure range for systet pump (s) in service as soon operation))

as possible.

JUSTIFICATION OF DIFFERENCE The difference between the steps aret (1) the pressure range for system operation is omitted in the PSTG step and (2) statements telling how to operate the systems are included in the PSTGs. The pressure range for system operation is omitted since it encumbers the procedure while providing little useful information. The operators are familiar enough with these systems so as not to need this information.

Note that HPCS is dropped from the system list since BFN does not have a HPCS.

Page 167 of 378

EPG Caution 9 and 10 are omitted frem the PSIGs for the reasons discussed in the

' cautions' section. EPG caution 11 is omitted here and included in the section dealing with Rx'depressurization. EPG caution #12 is reworded and incorporated here in the PSTGs as caution #3. An additional caution (EPG caution #21) is included here since this step pertaf5; to RCIC operation. EPG caution 8 dealing with RHR and CS pump NPSH requirements is also included here as part of the step since RHR and CS pump operation is called out here.

The RCIC system is normally lined up to the Condensate Storage Tank (CST). The operator is instructed to maintain this suction path. This action maintains RCIC lined up to a cooler, cleaner source of water. If the only systems that are operable are HPCI or RCIC, significant loss of AC power has occurred. No directions are currently given to switch RCIC suction to the suppression pool until either: 1) high suppression pool level is reached, or 2) low CST level is reached. However, by the time these conditions are reached, torus temperature will be near (if not in excess of) RCIC/HPCI operating temperature limits (NPSH, lube oil temperature).

Although shifting suction immediately to the suppression pool might gain you a 11ttle additiocal time, it was decided not to take that approach for the following reasons:

1) Increased proaedural complexity; in this situation the operators are going to have plenty to do without worrying about having to shif t RCIC or HPCI auction back and forth from the CST to the suppression pool.

2) Changes valve positions will deplete battery capacity faster. This could be a significant concern during a long duration station blackout.

3) There is a substantial amount of water available in the CSTs just for the purpose of supplying makeup water in situations such as these. In addition, refilling the CSTs during a station blackout is thought to be relatively simple, thus providing a source of water for longer term cooling.

This argument is also true for HPCI. The operator is instructed to maintain this suction path for HPCI even if suppression pool level exceeds the high level suction auto transfer if and only if suppression pool temperature exceeds 140*F. This interlock was not intended to operate under conditions of HPCI operation with suction from the torus and torus water temperature above 140*F. Per bases for technical specification 3.5E, HPCI is not assumed to operate from the suppression pool af ter suppression pool temperature exceeds 140*F since the required !TPSH is not available from the suppression pool without containment over pressure. Since this action is conditioned on temperature it does not violate technical specifications or any design basis assumptions and therefore does not constitute an unreviewed safety question.

Page 168 of 378 .

The RCIC system will isolate on low Rx pressure. However, in extremely degraded conditions, continued system operation may be obtained at Rx pressure below the isolatian setpoint but above turbine stall epeed by defeating the low Rx pressure isolation interlock. It is recognized that system performance (if any) will be much less thatt design, but circumstances are such that any flow produced by RCIC system operation must be obtained. Reference technical specification 3.2.A and 3.2.B. The low reactor pressure isolation is not required by technical specifications or the FSAR, but is installed for equipment protection. In a severely degraded condition this concern becomes less significant. Risking equipment damage at this point is justified if the RCIC system is being relied on to provide adequate core cooling.

)

Page 169 of 378 . ...

9

PSTG STEP EPG STEP RC/L-2.1 If Rx water level cannot If RPV water level cannot be restored be restored and maintained and maintained above (+12 in. (low above +11 in.-(low level level scram setpoint)], maintain RPV scram setpoint), maintain water level above (-164 in. (top of Rx water level above 0 in, active fuel)).

on Post Accident Flooding Range instruments (top af active fuel).

4 JUSTIFICATION OF DIFFERENCE The BTN specific action limits are inserted in the PSTGs. The baies for the limits remair.s unchanged.

Page 170 of 378 ,, ,,,

PSTG STEP EPG STEP

1. Rx water legal contral cay be aug- No corresptnding step. i mented by one or more of the follow-ing systems:

Condensate transfer pumps to RHR and CS 0 - 100 psis, 0 - 1000 gpm

- SLC (test tank) augmented by demineralized water head tank 0 - 1400 psig, 23 spm test tank capacity - 210 gallons demineralized water tank capacity - 30,000 gallons SLC (boron tank)

O to 1400 psig, O to 50 gpm storage tank capacity -

4500 gallons RHR crosaties to other units 0 to 310 psig, O to 5000 gpm

- Standby coolant 0 to 100 pois, O to 3500 gpm

- RHR drain pumps 0 to 40 psig, 0 to 600 gpm

- PSC head tank pumps O to 40 psig, O to 80 gpm

- RCIr. (using aux, boiler steam aux, boiler steam pressure O to 250 psig Rx pressure 0 to 350 psig, 600 gpm

- HPCI (using aux. boiler steam) aux. boiler steam pressure O to 250 psig Ft pressure O to 350 psig, f000 gpm t

l Page 171 of 378 , , , ,

v..- ..-., e-,-_.-_ , - - , - - , , . _ , -- , . - - - ~

' JUSTIFICATION OF DIFFERENCE This step is added for the 'ollowing reasons:

If Rx water level cannot be maintained above the low Rx water level scram setpoint any one or a combination of the above systems may be lined up and placed in se rvice. Included are those systems and system interconnections capable of injecting water into the Rx which are not normally utilized for this purpose because of low water quality or the relative difficulty of establishing the injection lineup.

If Rx water level had been restored with these systems as directed in Contingency

1. 1 (Alternate Level Control) and level control subsequently returned to the RC/L section, it is appropriate to continue injection with these systems as long as conditions require.

This step is added as a result of implementation concerns identified by utilities during development of revisions to the EPGs af ter Revision 3.

i 3

Page 172 of 378 , , , ,

i

PSTG STEP EPG STEP RC/L-2.2 If Rx water level can be If RPV water level can be maintained maintained above 0 in, on above (-164 in. (top of active fuel))

Post Accident Flooding and the ADS timer has initiated, prevent Range instruments (top of automatic RPV depressurization ty reset-active fuel) and the ADS ting the ADS timer, timer has initiated, pre-vent automatic Rx depres-surization by resetting the ADS timer.

b JUSTIFICATION OF DIFFERENCE The BFN action limits have been inserted in the PSTG. The basis remains unchanged.

Page 173 of 378 , , ,

4 PSTG STEP EPG STEP l

If Rx water level cannot be maintain- If RPV vater level cannot be maintained ed above 0 in. on Post Accident above (-164 in. (top of active fuel)],

Flooding Range instruments (top of enter [ procedure developed from active fuel), disable ADS auto CONTINGENCY #1).

blowdown function and enter the procedure developed from CONTINGENCY 1.

a JUSTIFICATION OF DIFFERENCE The ADS is disabled at this point in the PSTGs to eliminate the need for the t

operator to continue to reset the timer. This action is called out in C1,

' Alternate Level Control' if Rx water level drops below the ADS initiation setpoint. The reasoning here is that if the operator has made che decision that he will.not be able to maintain level above TAF (and hence will be entering Contingency 1) then he also obviously feels that level will drop below the ADS initiation setpoint. At that point, there is no reason not to disable ADS and free an operator from having to worry about resetting the ADS timer for any longer '

a period than is absolutely necessary.

)

Page 174 of 378 - ... ,

EITG STEP EPG SfEP No corresponding step. If Alternate Shutdown Cooling is required, enter (procedure developed from CONTINGEN0Y 45). .

1 JUSTIFICATION OF DIFTERENCE Alternate Shutdown Cooling (ASDC) is omitted from the PSTGs. Should shutdown cooling be required and be unavailable, Browns Ferry would employ whatever systems had been used to reduce pressure and to cooldown to begin with.

The reasons behind omitting Alternate Shutdown Cooling from the PSTGs are the following:

- There is some uncertainty as to whether the SRV tailpipes could withstand the stressos associated with discharging saturated liquia or 2 - phase flow. They have been tested for superheated steam and subcooled liquid and these fluid states present no problem. But there is a degree of uncertainty, and therefore risk, associated with discharging saturated liquid or 2 - phase flow, Under the conditions where ASDC is used, we do not feel the risk is worth tak',n..

Page 175 of 378 , , , ,

- ASDC is needed most where there is an unisolable primary system break inside primary containment. EPG Contingency 5 effectively raises pressure to implemnent ASDC, an action which increases inventory loss rate. There may be some benefit to flooding water out the break, but the bettes method is to continue injecting to maintain vrter level while steaming out the break or an open SRV. Therefore, the use of ASDC would not enhace conditions in an emergency situation.

Based on this reasoning, the PSTGs omit this contingency. This agrees with the action taken by the BWROG Emergency Procedures Subcommittee in development of EPG Rev. 4 1

J i

Page 176 of 378 -.

PSTU STEP EPG STEP If while executing steps RC/P-1 If while executing the following steps:

through RC/P-5:

EmergencyRPVDepressurizationl#13l

- A high drywell pressure ECCS is anticipated, rapidly initiation signal (2.45 psig depressurize the RPV with the (drywell pressure which initiates main turbine bypass valves.

ECCS)] exists, prevent injection from those CS and LPCI pumps not

• Emergency RPV Depressuriuation or required to assure adequate core RPV Flooding is required and less cooling prior to depressurizing than (7 (number of SRVs dedicated to below 320 psig (LPCI and CS pumps ADS)] SRVs are open, enter (proce-shutoff head), dure developed from CONTINGENCY #2).

- Emergency Rx depressurization 1121

• RPV Flooding is required and at is anticipated and all control least (7 (number of SRVs dedicated rods are inserted to or beyond to ADS)] SRVs are open, enter position 02 (Maximum Suberitical (procedure developed from Sanked Withdrawal Position), CONTINGENCY #6].

rapidly depressurize the Rx with the main turbine bypass valves.

- Emergency Rx depressurization is required, enter the procedure  !

developed from CONTINGENCY 2.

Rx water level cannot be deter-mined, enter the procedure dev-eloped frca CONTINGENCY 2.

JUSTIFICATION OF DIFFERENCE The first condition in the PSTG override does not have a corresponding step in the EPGs. The guidance provided here was removed from EPG caution 11 and incorporated here. This is because this guidance was in the form of an action statement and was inappropriate for inclusion in a caution. It is incorporated here in pressure ,

control where steps may direct pressure to be reduced below the shutoff head of  :

the CS and LPCI pumps.

Low pressure ECCS initiate automatically on a high drywell pressure signal and begin to inject when Rx pressure decreases below the shutoff head of the pumps.

320 psig is the shutoff head for both LPCI and CS. If injection from these pumps is not required to assure adequate core cooling, locking them out is appropriate since uncontrolled injection only complicates actions to maintain control of Rx water level. Additionally if the Rx is not shutdown, the positive reactivity added may be sufficient to induce a Rx power excursion.

Page 177 of 378 , ,

C;utien 13 ef the EPG3 is c2itted fron the PSTG3. S;e the ju:tificction in tho

' cautions' section of this document.

In the second bullet of the PSTG (Reference 1st bullet of the EPG step), the additional condition is added to ensure the reactor is shutdown before rapidly depressurizing. This is the wrong action in the event of an ATWS. The appropriate rapid depressurization steps during an ATWS are specified in C5 (Level / Power Control). 02 is the maximum suberitical banked withdrawal position for BFN.

Caution 2 of the PSTGs corresponds to Caution 7 of the EPGs. It is appropriate to provide a caution concerning unreliable level instruments during rapid depressurization at the step which may direct a rapid depressurization.

The difference between the second bullet of the EPG and the third bullet of the PSTG !s that "RPV flooding is required and less that (7 (number of SRVs dedicated to ADS)] SRVs are open" is omitted from the PSTGs. The reasons for this are:

RPV flooding is covered by the next bullet and contingency 2 vill specify opening the correct number of SRVs. All directions for Rx flooding are routed through contingency'2 in the PSTGs which assures emergency Rx depressurization takes place before flooding.

For the last bullets, Rx flooding is required in the PSTGs only when Rx water level cannot be determined. In revision 3 of the EPGs, Rx flooding was also required if drywell pressure reached a particular value. In this case, flooding water out the postulated break would aid in reducing dryvell pressure. Later studies by the ;r.ROG EPC have shown no additional containment pressure control benefits can ce obtained by intentionally flooding subcooled water out a break.

This is in accordance with draft rev. 4 of the EPGs. As previously stated, all flooding requirements are routed through contingency 2.

Page 178 of 378 , , , ,

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PSTG STEP EPG STEP RC/P-1 If any 3RV is cycling, RC/P-1 If any SRV is cycling, initiate manually open SRVs until Rx IC and manually open SRVs until pressure drops to 931.3 psis RPV pressure drops to (935 psig (Rx presrure at which all (RPV pressure at which all main turbine bypass valves turbine bypass valves are fully are fully open). open)].

IUSTIFICATION OF DIFFERENCE BFN does not have an isolation condenser. 931.3 psig is the reactor pressure at which all turbine bypass valves are fully open. t i

i Page 179 of 378

PSTG STEP EPG STEP If while executing steps RC/P-2 If while executing the following steps:

through RC/P-5:

Suppression pool temperature #8

- Steam Cooling is required, enter cannot be maintained below #13 the procedure developed from the Heat Capacity Temperature .3J4 .

CONTIhGENCY 3. Limit, maintain RPV pressure below the Limit.

Suppression pool water #13l level cannot be maintained . J.lA}.

below the Suppression Pool l Load Limit, maintain RPV pressure below the Limit.

Steam Cooling is required, enter (procedure developed from CONTIN- l GENCY #3.

JUSTIFICATION OF DIFFERENCE Cautions 8, 13, and 14 are omitted here. See the justifications contained in t.he l

' cautions' -action of this document.

In order to simplify the step, the directions to maintain Rx pressure below the Heat Capacity Temperature Limit and the Suppression Pool Load Limit are specified in containment contre ~ in SP/T and SP/L. They reference E0I-1 step RC/P which tells the operator which systems to use to maintain reactor pressure below the limits. This arrangement recomplishes the same objectives as in the EPGs but simplifies the procedure.

Page 180 of 378

PSTG STEP EPG STEP RC/P-2 Stabilize Rx pressure below RC/P-2 Control RPV pressure l#14l 1043 psig with the main below (1090 pais turbine bypass valves. (lowest SRV lifting pressure)] with the main turbine bypass valves.

J i

l JUSTIFICATION OF DIFFERENCE ,

i Caution #14 is omitted here. See the justification contained in the ' caution' section of this document.  ;

5 1043 psig is the Rx scram setpoint on high pressure. This value is chosen rather l than the SRV lifting pressure to allow :aset of RPS in the case of an ATWS.

I Stabilize is used rather than control because it more clearly describes the intent of the step.

P P

J d

Page 181 of 378 v e.. l

PSTC STEP EPG STEP RC/P-2.1 Rx pressure control may be RPV pressure control may be augmented augmented by orie or more by one ci more of the following of the following systems: systems:

SRVs only when suppression

• IC pool water level is above 5.5 '

SRVs or.ly when suppression pool ft. (elevation of top of SRV vater level is above (4'9" (eleva-  !

discharge device): open SRVs tion of top of SRV discharge in a sequence which will device)). If the continuous l#15l equalize heat distribution to SRV pneumatic supply is or the suppression pool (recom- becomes unavailable, depressurize mended SRV opening sequence); with sustained SRV opening, if Drywell Control Air and

• HPCI l#12l Control Air become unavailable

• RCIC place the centrol switch for * (Other steam driven equipment]

each SRV in the CLOSE or

• RWCU (recirculation mode) if no AUTO position. boron has been injected into the RPV.

RECOMMINDED SRV OPENING SEOUENCE

• Main steam line drains RWCU (blowdown mode) if no boron PCV-1-179 has been injected into the RPV.

PCV-1-180 Refer to (sampling procedures) prior PCV-1-4 _ _ . _ _

to initiating blowdown.

PCV-1-31 PCV-1-23 PCV-1-42 PCV-1-30 PCV-1-19 <

PCV-1-5 __

PCV-1-41 PCV-1-22 PCV-1-18 PCV-1-34 HPCI with suction from 1111 the CST if possible.

RCIC with suction l#3. #4l from the CST if possible.

Steam line drains.

RWCU (blowdown mode) only if no boron has been injected into the Rx and no gross fuel failure is suspected.

Page 182 of 378

INTRODUCTION The purpose of this document is to identify the differences between the Browns Ferry Plant Specific Technical Guidelines and the generic Emergency Procedure Guidelines. These differences can be due to:

- different plant equipment

- different operating characteristics

- different plant design or differences other than those identified above that are potentially safety significant.

This document is laid out in a two-column format. The PSTG step is shown in the first column and the comparable EPG step is shown in the second column (where applicable). Following the two steps is the justification for the difference between the two steps. This document is not intended to document all of the differences between these two guidelines. Differences that are editorial in nature or differences in nomenclature are not contained in this document. .

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Page 131 of 378 . ,

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_ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _____-m

1 CAUTIONS i

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Page 132 of 378 . . . .

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PSTG STEP E SIgg No corresponding caution. Caution #1 Monitor the general state of the plant.

If any entry condition for a (procedure developed from the Emergency Procedure Guidelinesi occurs, enter that procedure. When it is determined that an emergency no longer exists, enter (normal operating procedure].

l JUSTIFICATION OF DITTERENCE This caution has been removed from the PSTGs and placed in Plant Managers Instruction, PMI-12.12. "Conduct of Operations" in order to avoid cluttering up the PSTGs. It is not necessary to incorporate this caution in the PSTGs because all operators are trained to monitor the general state of the plant and when to enter and exit the E0Is.

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Page 133 of 378 l

PSTG STEP EPG STEP No corresponding step. If RPV cooldown is required but cannot be accomplished and all control rods are inserted beyond position (06 (maximum suberitical banked withdrawal position)], ALTERNATE SHUTDOWN C00LIN",'

IS REQUIRED; enter (procedure developed from CONTINGENCY #5).

JUSTIFICATION OF DIFFERENCE Alternste Shutdown Cooling is not implemented at BFN for the reasons discussed in EPG override preceding step RC/L-3.

Page 187 of 378 j . - . _ . . . . .

PSTG STEP EPG STEP RC/P-5 When all control rods are RC/P-5 Proceed to cold shutdown in inserted to or beyond pos- accordance with [ procedure ition~02 (Maximum Suberitical for cooldown to cold shut-Banked Withdrawal Position) dovn conditions),

or 669 pounds of boron (Cold Shutdown Boron Weight) have been injected into the Rx, proceed to cold shutdown in accordance with GOI-100-12 (procedure for cooldown to cold shutdown conditions).

JUSTIFICATION OF DIFFEREECJ It is appropriato to wait until ic is assured the reactor is shutdown and will rema!n so before pr:ceeding to cold shutdown.

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l Page 188 of 378

PSTG STEP EPG STEP RC/Q-1 If a Rx scram has not been No corresponding step in RC/Q.

initiated, initiate a Rx scram. /

/USTIFICATION OF DIFFERENCE Moving of step from RC to RC/Q is done in order to put all action stepr, cogether in RC/L, RC/P, and RC/Q. Since RC/Q RO/L, and RC/P are all entered and executed concurrently, this step will still be the first one executed. Also, recognizing that all Rx Guideline entry conditions correspond to scram setpoints (wich the possible exception of MSIV isolation with the nnde switch in STARTUP), entr" inco

. the Rx Control Guideline means that a scram should have taken place. The operator noting this, will initiate a Rx scram (if one has not been initi..ted) even before entry into the 3CIs can be achieved. Therefore, relocating thia step to RC/Q will not delay initiation of a Rx scram.

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Page 189 of 378 r . .

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PSTG STEP EPG STEP If while executing steps RC/Q-1,1 If while executing the following steps:

through RC/Q-5:

All control rods are inserted

- All control rods are inserted to beyond position (06 (Maximum sub-or beyond position 02 (Maximum critical banked withdrawal position)]

Suberitical Banked Withdrawal terminate boron injection and enter Position), terminate boron (scram procedure].

injection and enter GOI-100-11 (scram-procedure).

• The reactor is shutdown and no boron has been injected into the The Rx is shutdown and no boron RPV, enter (scram procedure].

has been injected into the Rx, enter GOI-100-ll (scram procedure).

JUSTIFICATION OF DIFFERENCE 02 is the maximum suberitical banked vi'.hdrawal posit!.an for BFN. GOI-100-11 is the scram procedure.

Page 190 of 378 g 4,4 m *9*e =

PSTG STEP EPG STEP RC/Q-3.1 If the main condenser is not No corresponding step, available as a heat sink or heat is being added to the suppression pool, place all available RHR loops in the suppression pool cooling mode using only those RHR pumps not required to assure adeq'date core cooling by continuous operation in the LPCI mode.

J.114"dFICATICJL9F DIFFERidLCJ This step is taken frcm Containment Control, step SP/T. In the event of an ATWS it is extremely imporcant to get ao many RHR pumps in the suppression pool cooling mode as quickly as poasible. The step is duplicated here to prevent the operator fram concentrating solely on EDI-1 and neglecting the 3P/T steps in E0I-2 until tco late. This causes no disagreement with the actions in the EPGs and thus constitutes no significant difference. The 6uidance that was contained in EPG caution 13 is incorporated here in this step to indicate the priority of operating mcdes for RHR.

Page 191 of 378

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PSTG STEP EPG STEP RC/Q-4 IF the Rx cannot be shutdown RC/Q-4 If the reactor cannot lI/19 l before suppression pool temp- be shutdown before erature reaches 110 degrees F suppression pool temp-(Boron Injection Initiation erature reaches (110*F (Boron Temperature), BORON INJECTTON Injection Initiation Tempera-IS REQUIRED; inject boron ture)], BORON INJECTION IS into the Rx with SLC and REQUIRED: inject boron into disable ADS auto blowdown the RPV with SLC and prevent function. automatic initiation of ADS.

JUSTIFICATION OF DIFFERENCE Caution 19 is an action rather than a caution and therefore is implemented as a step override immediately preceding step RC/Q-4.3. Per bases for the EPG step, prev 2nt means defeat the ADS logic. Disable is in agreement with this interpretation.

Page 192 of 37d g e * #4 % a

PSTG STEP EPG STEP RC/Q-4.1 If boron cannot be injected If boron cannot be injected with SLC, with SLC, -inject boron into inject boron into the RPV by one or the Rx by one or more of more of the following alternate the folicwing alternate methods:

methods:

CRD

- RCIC

• HPCS

• RWCU RWCU

• Feedwater HPCI RCIC Hydro Pump JUSTIFICATION OF DIFFERENCE The choice of alternate boron injection systems was based on possible failure modes for SLC. In other words, the choice of the system for alternate boron injection had to be capable of injecting boron irrespective of the failure mode of SLC.

The possible failure modes for SLC can be classified into two general cater, ries:

1) Loss of solution - Due to tank rupture, solution crystallization cause.1 by loss of heaters, any event which prevents the solution from being pumped into the vessel (assuming all other system components are functioning properly)

2) Failure of the system to inject the solution into the vessel excluding part

1) concerns. These tjpes of failures include, but ere not limited to loss of power, loss of system integrity, flow blockage, others To cover failures describes under part 11 tbove, the RWCU system vill, be used to inject codium pentaba; ate solution.

That system provides the capability of mixing fresh solution in the RWCU precoat tank and injecting via the normal flow path to the vessel.

If the failure is one that fits under part 2) above, the RCIC system can be used to inject boron. A suction hose will be routed from the SLC tank drain to RCIC pump suction and injected using RCIC.

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! Page 193 of 378

PSTG STEP EPG STEP If while executing steps RC/Q-4.3 No corresponding step.

through RC/Q-4.4 SLC tank level drops to 0%, manually trip the SLC pumps.

JUSTIFICATION OF DIFFERENCE This action implements the implied action of EPG caution 19 as an override at the steps where Boron injection is taking place. It is pr'2 dent to trip the SLC pumps before the SLC pump suction inlet becomes uncovered to prevent possible mechanical damage to the pumps. This preserves the availability of the system should operation of the system again be needed.

Page 194 of 378 e

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PSTG STEP .EPG STEP RC/Q-4.3 Continue to inject boron RC/Q-4.2 Continue to inject boron

'intil 669 pounds (Cold until (280 pounds (Cold S'tutdown Boron Weight) of Shutdown Boron Weight)] of boron have been injected boron have been injected into into the Rx. the RPV.

JUSTIFICATION OF DIFFERENCE

'669 pounds of boron corresponds to the Cold Shutdown Boron Weight for BFNP.

1 Page 195 of 378

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PSTG STEP EPG STEP RC/Q-4.4 When 669 pounds ' of Boron RC/Q-4.3 Enter (scram procedure). l (Cold Shutdown Boron  :

I Weight) have been injected into the Rx, enter GOI-100-11 (scram pro-cedure).

JUSTIFICATION OF DIFFEREHEE It is appropriate to wait until reactor shutdown is assured to enter the scram procedure.

Page 196 of 378 e

PSTG STEP EPG STEP RC/Q-5 Insert control rods as RC/Q-5 Insert control rods as follows:

follows:

RC/Q-5.1 If any scram valve is

. RC/Q-5.1 If any scram valve not open:

is not open:

[ Remove:

1. Remove: H11-P609 C71-F18A, E, C, G Panel 9-15 5A-F18A, E, H11-P611 C71.-F18B, F, D, H C, G (fuses which de-energize Panel 9-17 S A-F18 B , F , RPS scram solenoids)].

D, H Close (C11-F095 (scram air (fuses which de-energize header supply valve)) and RPS scram solenoids) open (C11-F008 (scram air header vent valve)].

2. Close 85-331 (scram air header isolation valve) When control rods are not and open the instrument moving inward:

drain valves for instruments PS-85-38 and *

[ Replace:

PI-85-38 (scram air H11-P609 C71-F18A, E, C, G header vent valves). H11-P611 C71-F18B, F, D, H When control rods are not (fuses which de-energize moving inward: RPS scram solenoids)].

1. Replace: -

Close [C11-F008 (scram air Panel 9-15 SA-F18A, E, header vent valve) and open C, G (C11-F095 (scram air header supply valve)].

Panel 9-17 5A-F18B, F, D, H (fuses which de-energize RPS scram solenoids)

2. Close the instrument drain valves for instruments PS-85-38 and PI-85-38 (scraa air header vent valves) and open 85-331 (scram air header isolation valve).

JUSTIFICATION OF DIFFERENCE The BFN specific fuses which de-energize the RPS scram solenoids and the valves used to isolate and vent the scram air header are inserted in the PSTGs.

Page 197 of 378

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PSTG STEP EPG STEP RC/Q-5.2 Reset the Rx scram. If the RC/Q-5.2 Reset the reactor scram.

Rx scram cannot be reset, -

continue in this procedure If the reactor scram cannot be at step RC/Q-5.5. reset:

NOTE: PSTG step RC/Q-5.5 is shown 1. Start all CRD pumps, following for clarification.

If no CRD pump can be RC/Q-5.5 Manually insert control ' started, continue in this rods as follows: procedure at (step RC/Q-5.6.1].

If while executing steps RC/Q-5.5.1 through RC/Q-5.5.4 the Rx scram can 2. Close (C11-F034 (HCU accum-be reset and control rods moved ulator charging water head-inward following the last scram, er valve)].

reset the Rx scram and return to step RC/Q-5.3. 3. Rapidly insert l#20l control rods

1. Align and place in manually until the service all available reactor scram can be reset.

CRD pumps.

4. Reset the reactor scram.

If no CRD pump can be started, continue in 5. Open [C11-F034 (HCU this guideline at step accumulator charging water RC/Q-5.5.4. header valve)].

2. Close 85-586 (CRD .

Charging Water Header Isolation Valve).

3. Rapidly insert control rods manually, defeating RSCS interlocks if necessary.

4. If any control rod cannot be inserted to or beyond positien 02 (Maximum Sub-critical Banked With-drawal Position), locally vent the withdraw line for that control rod to a contained radwaste drain until it is not moving inward.

Page 198 of 378

JUSTIFICATION OF DIFFERENCE The actions spelled out in PSTG RC/Q-5 and EPG RC/Q-5 are essentially the same; however, the location of some of the steps is different. In the case of the EPG, there are two sections of RC/Q-5 where the operator is directed to manually insert control rods; RC,'Q-5.2 and RC/Q-5.5. The difference between these two is that in RC/Q-5.2 the operator is inserting rods manually until the Rx scram can be reset, then re-aligning CRD and scramming the Rx again. In RC/Q-5.5 the direction is to align CRD for manual rod insertion again but this time if rod insertion cannot be achieved from the control room, the CRD overpiston area is vented to insert the rods. In the PSTG, all of the manual rod insertion actions are included in step RC/Q-5.5. In addition, an override has been added that directs the cperator back to.the appropriate step if, while manually inserting rods, the Rx scran can be reset. Logically, the step sequences here are very similar. The redundancy in specifying the manual rod insertion actions is eliminated in the PSTG therby simplifying the procedure both from the standpoint of understandability and useability.

EPG step RC/0.-5.6.1 corresponds to PSTG step RC/Q-5.5.4.

Page 199 cf 378

ESTG STEP EPG STEP RC/Q-5.3 Drain the scram discharge RC/Q-5.3 If the scram discharge volume volume, verify or open vent and drain valves are 85-586 (CRD Charging Water open, initiate a manual Header Isolation Valve), reactor scram.

and initiate a manual scram. 1. If control rods moved inward, return to (step

1. If_ control rods moved RC/Q-5.2]'.

inward, return to step RC/Q-5.2. 2. Reset the reactor scram.

2. Reset the Rx scram. If If the reactor scram can-the Rx scram cannot be not be reset, continue in reset, continue in this this procedure at (step procedure at step RC/Q-5.5.1].

RC/Q-5.5.

3. Open the scram discharge

3. Verify or open the volume vent and drain scram discharge volume valves.

vent and drain valves.

JUSTIFICATION OF DIFFERENCE The PSTG step directs the SDV to be drained somewhat prior to initiating another scram. This is so there will be volume svailable in the SDV for the water displaced from the subsequent scram.

The word "verify" is added to step RC/Q-5.3.3. This is appropriate since the SDV vent ano drain valves should re-open once the scram is reset.

Directing the operator to EPG step RC/Q-5.5.1 is equivalent to directing the operator to step RC/Q-5.5 in the PSTG.

Page 200 of 378 1 .. .

E1I9 STEP EEG STEP RC/Q-5.4 Individually open the RC/Q-5.4 Individually open the scram scram test switches for test switches for control control rods not inserted rods not inserted beyond to or beyond position 02 position (06 (Maximum (Maximum Suberitical Suberitical Banked Withdrawal Banked Withdrawal Position)].

Position).

When a control rod is not

1. When a control rod is moving inward, close its not moving inward, scram test switch, close its scram test switch.

JUSTIFICATION OF DIFFERENCE The maximum suberitical banked withdrawal position for BFN is 02.

Page 201 of 378

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PSTG STEP EPG STEP RC/Q-5.5 Manually insert control RC/Q-5.5 Reset the reactor scram, rods as follows:

If while executing steps RC/Q-5.5.1 through RC/Q-5.5.4 the Rx scram can be reset and control rods moved inward follow-ing the last scram, reset the Rx scram and return to step RC/Q-5.3.

JUSTIFICATION OF DIFFERENCE EPG step RC/Q-5.5 and RC/Q-5.6 are incorporated in PSTG step RC/Q.5.5. The difference between the steps is the action taken if the Rx scram can be reset. .In the earlier steps of section RC/Q-5, if the Rx scram could be reset attempta were made to scram the Rx again. At this point in RC/Q-5 if the scram en be reset, the operator is directed to rapidly insert control rods. The PSTG step directs the operator to manually insert control rods unless (as provided by the override) the scram can be reset and control rods moved inward during the last scram. If the Rx scram can be reset, the appropriate action is to attempt to re-scram the Rx since this should cause the insertion of multiple rods instead of one rod at.a time. If the scram cannot be reset, the actions in the PSTG parallel those in the EPG.

Page 202 of 378 9

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PSTG STEP EPG STEP RC/Q-5.5 1. Align and place in RC/Q-5.5 If the reactor scram cannot service all available be reset:

CRD pumps.

1. Start all CRD pumps.

If no CRD pump can be started, continue in If no CRD pump can be this procedure at step started, continue in this RC/Q-5.5.4. procedure at (step RC/Q-5.6.1).

2. Close 85-586 (CRD Charging Water Header 2. Close (C11-F034 (HCU Isolation Valve). Accumulator Charging Water Header Valve)).

3. Rapidly insert control rods manually, defeating RC/Q-5.6 Rapidly insert control l#20l RSCS interlocks if rods manually until necessary, all control rods are inserted beyond position (06

4. If any control rod (Maximum Suberitical Banked cannot be inserted to Withdrawal Position)).

or beyond position 02 (Maximum Suberitical If any control rod cannot be Banked Withdrawal inserted beyond position Position), locally vent (06 (Maximum Suberitical the withdraw line for Banked Withdrawal Position)]:

that control rod to a contained radwaste drain 1. Individually direct the until it is not moving effluent from (C11-F102 inward. (CRD withdraw line vent valve)) to a contained radwaste drain and open (C11-F102 (CRD withdraw line vent valve)) for each control rod not inserted beyond position (06 (Maximum Suberitical Banked Withdraval

< Position)).

2. When a control rod is not moving inward, close its (C11-F102 (CRD withdraw line vent valve)).

Page 203 of 378

-n-. - - . - - - -ve w .--,-----,r-- -- - - - -

JUSTIFICATION OF DIFFERENCE The previous override directs action in the PSTG away from this step if the Rx scram can be reset, therefore it is unnecessary to carry the words here. PSTG step RC/Q-5.5.4 accomplishes the same actions as EPG step RC/Q-5.6.1. The BFN specific charging water header isolation valve is specified.

The guidance from EPG caution 20 is incorporated in the PSTG step. The condition until all control rods are inserted beyond the Maximum Suberitical Banked Withdrawal Position is dropped from the PSTG step since the next step is contingent on all rods being in past their Maximum Suberitical Banked Withdrawal Position.

The maximum suberitical banked withdrawal position for BFN is 02.

The PSTG step says "locally vent the withdraw line for that control rod. . .

until". This implies venting then closing the vent. Valves are not specified in the PTSG because more specific directions will be decided on and supplied in the procedure to meet the intent of this step.

t Page 204 of 378

___,___, _ , _ -,_m----_ , . - - -- - e--- - -

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'I PRIMARY CONTAINMENT CONTROL GUIDELINE Page 205 of 378

PSTG STEP EPG STEP ENTRY CONDITIONS ENTRY CONDITIONS The entry conditions for this guide- The entry conditions for this guideline line are any of the following: are any of the following:

- Suppression pool temperature above

• Suppression pool temperature above 95 degrees F (most limiting sup- [95'F (most limiting suppression pool pression pool temperature LCO) temperature LCO)]

- Drywell temperature above 160

• Drywell temperature above (135'F degrees F (maximum normal operating (drywell temperature LCO or maximum temperature) normal operating temperature, which-

- Drywell pressure above 2.45 psig ever is higher)]

(high drywell pressure scram set-

• Containment temperature above (90*F point) (containment temperature LCO)]

- Suppression pool water level above

• Drywell pressure above (2.0 psig

-1 in. (maximum suppression pool (high drywell pressure scram set-water level LCO) point)]

- Suppression pool water level below

• Suppression pool water level above

-6.25 in. (minimum suppression pool (12 ft. 6 in. (maximum suppression water level LCO). pool water level LCO)]

• Suppression pool water level below (12 ft. 2 in. (minimum suppression pool water level LCO)]

JUSTIFICATION OF DIFFERENCE The Browns Ferry plant specific numbers are inserted. Since BFN has Mark I centainment, a containment temperature entry condition (which applies to Mark III containments) is not applicable and is therefore omitted.

Page 206 of 378 O

PSTG STEP EPG STEP OPERATOR ACTIONS OPERATOR ACTIONS Irrespective of the entry conditions, Irrespective of the entry condition, execute steps SP/T, DW/T, PC/P, and execute [ steps SP/T, DW/T, CN/T, PC/P, SP/L' concurrently. and SP/L] concurrently.

s JUSTIFICATION OF DIFFERENCE The reference to step CN/T is omitted since that deals only with Mark III

, containments and BFN design utilizes Mark I containments.

Page 207 of 378

/

PSTG STEP EPG STEP No corresponding step

• SP/T-1 Close all SORVs.

If any SORV cannot be closed

[within'2 minutes (optional {

plant-specific time interval)],

scram the reactor.

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n JUSTIFICATION OF DIFFERENCE Thiu step is omitted since it is related to a specific event (a stuck-open relief valve). Stuck open relief valve events are b.andled in the Abnormal section of 0I-1.

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Page 208 of 378 e

i PSTG STEP EPG STEP SP/T-1 W5en suppression pool tempera- SP/T-2 When suppression pool 11111 t re exceeds 95 degrees F temperature exceeds (most limiting suppression (95'F (most limiting pool temperature LCO), suppression pool temperature operate all available suppres- LCO)], operate available sup-sion pool cooling using only pression pool cooling.

those RHR pumps not required to assure adequate core cool-ing by continuous operation in the LPCI mode.

JUSTIFICATION OF DEE]ll3pKI The caution 18 is incorporated into the step since it specifies an action or prevents action rather than advising.

Page 209 of 378 o

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PSTG STEP EPG STEP SP/T-2 Before suppression pool temp- SP/T-3 Before suppression pool temper-erature reaches 110 degrees ture reaches (110'F (Boron F (Boron Injection Initiation Injection Initiation Tempera-Temperature), but only if a ture)], scram the reactor.

Rx scram has not been initiated, initiate a Rx scram.

F JUSTIFICATION OF DIFFERENCE In the event of an ATWS a scram may have already been initiated but was unsuccessful. In this case, scramming the reactor again could interfere with other efforts to insert rods. Hence the additional phrase.

Page 210 of 378 O

PSTG STEP EFG STEP SP/T-3 If suppression pool tempera- SP/T-4 If suppression pool #8 ture cannot be maintained be- temperature cannot be #13 low the Heat Capacity Tempera- maintained below the _JDJL.

ture Limit (see Figure F), Heat Capacity Temperature -

maintain Rx pressure below the Limit, maintain RPV pressure limit in accordance with the below the Limit.

procedure developed from RC/P; enter the procedure developed from the Rx Control Guideline at stepa RC/L RC/P, and RC/Q 3

and execute it concurrently with this procedure.

JUSTIFIQ CJAN OF DIFFERENCE RC/L, RC/P, and RC/Q provide the directions for maintaining reactor pressure.

Cautions 8, 13, and 14 ere omitted here. See the discussions in the ' cautions' section for the appropriate justifications.

Page 211 of 378

PSTG STEP EPG STEP SP/T-4 If suppression pool tempera- If suppression pool temperature and ture and ix pressure cannot RPV pressure cannot be restored and be restored and maintained maintained below the Heat Capacity below the Heat Capacity Temp- Temperature Limit, EMERGENCY RPV DE-erature Limit (see Figure F), PRESSURIZATION IS REQUIRED; enter EMERGENCY RX DEPRESSURIZATION [ procedure developed from the RPV IS REQUIRED. Control Guideline) at (step RC-1] and execute.it concurrently with this procedure.

JUSTIFICATION Of DIFFERENCE In the previous step, SP/T-3, we have already directed pressure to be controlled per RC/P. Therefore, if we need to Emergency Depressurize, c!.w steps in RC/P will ditect that action.

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l Page 212 of 378 4

• g 9

PSTG STEP EPG STEP DW/T-1 When drywell temper- M DW/T-1 When dryve).1 temperature M ature exceeds 160 exceeds [135'F (drwell degrees F (Maximum Normal temperature LCO or maximum Operating Temperature), normal operating temperature, operate all available drywell whichever is higher)], operate cooling. available drywell cooling.

F JUSTIFICATION OF DIFFEREFIE The Browns Ferry specific value for Maximum Normal Operating Temperature is inserted. The differences between EPG caution 6 and PSTG caution 1 are discussed in the ' Cautions' section of this document.

Page 213 of 378 4

pe er s e e =w ..

1 PSTG STEP EPG STEP No corresponding step. Execute [ steps DW/T-2 and-DW/T-3) concurrently.

JUSTIFTCATION OF DIFFERENCE EPG step DW/T-2 is omitted from the.PSTGs (see explanation following step DW/T-2). Since this step does not apply to our P.9TGs, this override is unnecessary.

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1 Page 214 of 378

~ _-. _.___,..._,_ _ _ _..--_.._.. ~ -

PSTG STEP EPG STEP No corresponding step. DW/T-2 If dryvell temperature (near the i cold reference leg instrument vertical runs] reaches the RPV Saturation Temperature, RPV FLOCDING IS REQUIRED; anter (procedure developed from the RPV Control Guideline] at (step RC-1} and execute it concur-rently with the procedure developed from this guideline.

JUSTIFICATION OF DIFFERENCE The purpose of the EPG stap is to . require flooding if Rx water level cannot be determined. Level cannot be, determined if dryvell temperature near the reference legs exceeds the Rx Saturation Temperature. For the PSTG, this guidance has been incorporated into caution #1. If Rx water level cannot be determined using the guidance contained in caution #1, the Rx would be flooded per the directive in RC/L.

t Page 215 of 378 g %A g w = seme =..

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PSTG STEP EPG SIRE If while executing' steps DW/T-2 and No corresponding step.

DW/T-3 drywell pressure drops below 2.45 psig (high drywell pressure scram setpoint), stop drywell sprays.

A JHSTIFICATION OF DIFFERENCE This PSTG override is added because the following steps direct the use of drywell sprays to reduce the drywell. temperature. If drywell sprays continue to be used, it is possible to convectively cool the drywell below its negative design pressure capability or below the drywell to torus boundary capability, thus damaging primary containment. This step helps prevent this possibility. The high drywell pressure scram setpoint is chosen because it is sufficiently above the primary containment negative pressure capabilities yet it assures that in the case of an ATWS, the RPS cannot be prevented from being reset by the drywell pressure, Page 216 of 378 e e %= .

PSTG STEP EPG STEP DW/T-2 Before drywell temperature DW/T-3 Before drywell temperature reaches 281 degrees F (drywell reaches (340*F (maximum temper-design temperature) but only ature at which ADS qualified or if the following conditions drywell design temperature, exist: whichever is lower)) but only if [ suppression chamber tempera- ,

- Suppre sion chamber temper- ture and drywell pressure are  !

ature and drywell pressure below the Drywell Spray Initial-are within the Drywell Spray tion Pressure Limit], (shut Initiation Limit (see Figure down recirculation pumps and C) AHD drywell cooling fans and) initiate drywell sprays (re-

- Suppression pool water level stricting flow rate to less than is at or below 18 feet 720 gpm (Maximum Drywell Spray (elevation of bottom of Flow Rate Limit)).

internal suppression cham-ber to drywell vacuum breakers less vacuum breaker opening pressure in feet of water).

DW/T-2.1 Shut down reactor recire-ulation pumps.

DW/T-2.2 Shut down drywell blowers.

DW/T-2.3 Initiate drywell sprays using only those RHR pumps not required to assure adequate core cooling by continuous operation in the LPCI mode.

JUSTIFICATION OF DIFFERFJi.C3 ,,

The BFN drywell design temperature is 281*F. The plant specific drywell spray initiation limit calculation is documented in the Appendix C-9.0 calculation. The Appendix C-8.0 calculation shows the maximum drywell spray flow limit is not a concern for BFN. EPG caution 18 is incorporated in PSTG DW/T-2.3. Use of drywell sprays is additionally conditioned on suppression pool level being below the level of the internal drywell to torus vacuum breakers less the height of water

corresponding to the 0.5 psid opening pressure differential. This was added to ensure the vacuum breakers will function during use of drywell sprays to ensure the. drywell does not fail due to an excess negative pressure differential.

Page 217 of 378 G

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PSTG STEP EPG STEP DW/T-3 If drywell temperature cannot If drywell temperature cannot be main-be maintained below 281 tained below (340*F (maximum tempera-degrees F (drywell design ture at which ADS qualified or drywell temperature), EMERGENCY RX design tempera *.vre, whichever is DEPRESSURIZATION IS REQUIRED; lower)], EMERGENGY RPV DEPRESSURIZATION enter the procedure developed IS REQUIRED; enter (procedure develop-from the Rx Control Guideline ed from the RPV Control Guideline) at at steps RC/L, RC/P, and RC/Q [ step RC-1] and execute it concurrently and execute it concurrently with this procedure, with the procedure developed from this guideline.

JUSTIFICATION OF DIFFERENCE 281*F is the Browns Ferry drywell design temperature. Directing entry into RC/L, RC/P, and RC/Q from this step serves the same purpose as the EPG step (see justification for deleting step RC-1 from the PSIGs located in the front of the La Control Guideline section of this document).

Page 218 of 378 4

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PSTG STEP EPG STEP No corresponding step. CN/T Monitor and control containment temperature.

CN/T-1 When containment M temperature exeeds (90*F (containment temperature LCO)], operate available con-tainment cooling.

CN/T-2 Before containment l#18l temperature reaches (185'F (containment design temperature)] but only if (suppression chamber pressure is above 1.7 psig (Mark III Containment Spray Initiation Pressure Limit)], initiate

, suppression pool sprays.

CN/T-3 If containment temperature cannot be maintained below (185'T (containment design temperature)], EMERGENCY RPV DEPRESSURIZATION IS REQUIRED; enter (procedure developed

, from the RPV Control Guide-line) at (Stop RC-1] and execute it concurrently with the procedure developed from this guideline.

CN/T-4 If containment temperature (near the cold reference leg ,

instrument vertical runs]

reaches the RPV Saturation

,. Temperature, RPV FLOODING IS REQUIRED.

JUSTIFICATION OF DIFFERENCE These steps are applicable only for Mark III containments. BFN has Mark I containments.

Page 219 of 378 4

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PSTG STEP EPG STEP PC/P-1 Operate the following systems PC/P-1 Operate [the following systems, as reov. ired: as required:

- Containment atmosphere

• Containment pressure control dilution systems. Use containment pressure control system op-

- Standby Gas Treatment System erating procedure].

only when the temperature

• SGTS (and drywell l#21l in the space to be evacuated purge], only when the is below 212 degrees F temperature in the space being (Maximum Nortcondensible evacuated is below (212*F Evacuation Temperature). (Maximum Noncondensible Evacu-ation Temperature)). Use (SGTS and drywell purge oper-ating procedures).

JUSTIFICATION OF DIFFERENCE The reference to ' Containment pressure control systems' is applicable to Mark III containments and is therefore omitted here.

The SGTS and CAD systems are used at Browns Ferry to control primary containment pressure.

Caution #21 is omitted here. See the justification outlined in the ' caution' section of this document for an explanation.

The Primary Containment Purge System is not included here has a means of controlling pressure. This system is designed only for inerting and de-inerting primary containment.

Pace 220 of 378 4

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PSTG STEP EPG STEP 1

PC/P-1.1 Verify or place in service No corresponding step. l H2/02 Analyzers. )

1 PC/P-1.2 If a group 6 isolation exists, use keylock bypass switch on H2/02 analyzer ptuels to monitor drywell and suppression chamber concentrations.

PC/P-1.3 If hydrogen is indicated, refer to OI-84 (crocedure for controlling H2 concern-tration).

JUSTIFICATION OF DIFFERENCE The FSAR specifies the use of Containment Atmosphere Dilution (CAPI system to dilute the primary containment atmosphere following a LOCA in order to maintain H2 and 02 concentrations below 4% and 5% respectively. In order for the operator to l

know when to employ the CAD system, he must be able to determine H2 and 02 l levels. The inclusion of the above steps ensures that the Containment Atmosphere Monitoring (CAM) system is available and allows the rip.rator to be able to obtain

!!2 and 02 concentration readings from the primary containment.

Page 221 of 378 4

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F.EIG STEP EPG STEP If while executing steps PC/P-2 No corresponding step.

through PC/P-6 suppression pool sprays have been initiated and suppression chamber pressure drops below 2.45 psig (high drywell pressure scram setpoint), stop j suppression pool sprays.

s JUSTIFICATION OF DIFFERENCE t

In the following steps, suppression pool sprays may be initiated to preclude chugging. The operation of suppression pool sprays is terminated when suppression chamber pressure decreases to the high drywell pressure scram setpoint to assure that primary containment pressure is not reduced below atmospheric. Maintaining a i

positive suppression chamber pressure precludes air from being drawn in through i

the vacuum relief valves to de-inert the primary containment, and also assures a i

positive margin to the negative design pressure limit.

Pegd 222 of 378

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h PSTG STEP EPG STEP PC/P-2 Before suppression chamber PC/P-2 Sefore suppression l#8. #181 pressure reaches 14.5 psig chamber pressure reaches (Suppression Chamber Spray (the Pressure Suppression Pres-Initiation Pressure) but only sure) (17.4 psig (Suppression if suppression pool water Chamber Spray Initiation Pres-level is below 20 ft. (ele- sure)), but only if (suppression vation of suppression pool chamber pressure is above 1.7 spray nozzles), initiate psig (Mark III Containment Spray suppression pool sprays using Initiation Pressure Limit)]

only those RHR pumps not re- (suppression pool water level is quired to assure adequate core below 24 ft. 6 in. (elevation cooling by continuous opera- of suppression pool spray tion in the LPCI mode. nozzleo)], initiate suppression pool sprays.

JUSTIFICATION OF DIFFERENCE 14.5 psig is the suppression chamber spray initiation pressure per Appendix C-11.0 and is more limiting than the Pressure Suppression Pressure (Appendix C-12.0_).

BFN is a Mark I containment, therefore the Mark III Containment Spray Initiation Pressure Limit is not applicable. The 20 ft. level specified for the suppression pool spray nozzles is somewhat below the actual nozzle location (26 ft. 10 in.).

20 ft. is the maximum level that can be read on existing control room instrumentation. This additional margin makes our guideline more conservatuive chan the generic EPG by further restricting the region in which suppression pool bprays can be used. Caution 18 is incorporated into the PSTG steps while caution 8 is omitted here. See the ' cautions' section for justification on omission of caution 8.

Page 223 of 378

PSTG STEP EPG STEP If while executing steps PC/P-3 No corresponding step.

through PC/P-6 drywell sprays have been initiated and drywell pressure drops below 2.45 psig (high drywell pressure scram setpoint), stop dryvell sprays.

JUSTIFICATION OF DIFFERENCE l In the following step, drywell sprays are directed to be used. This override is l

added to assure the drywell is not taken negative relative to atmospheric pressure and thus maintain margin to the drywell negative containment design pressure and l to the negative dryvell to torus differential pressure. The high drywell pressure l scram setpint is chosen as the action limit to assure for ATWS events that high dryvell pressure won't prevent the resetting of RPS.

I Page 224 of 378 9

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e PSTG STEP EPG STEP PC/P-3 If suppression chamber pres- PC/P-3 If suppression chamber l#18l sure exceeds 14.5 psig pressure exceeds-(Suppression Chamber Spray (17.4 psig (Suppression Initiation Pressure) but only Chamber Spray Initiation Pres-if the following conditions sure)] but only if (suppression exist: chamber temperature and drywell pressure are below the Drywell

- Suppression chacher temper- Spray Initiation Pressure Limit]

ature and drywell pressure (shut down recirculation pumps are within the Drywell and drywell cooling fans and]

Spray Initiation Limit initiate dryvell sprays (see Figure C) AHD [ restricting flow rate to less than 720 gpm (Maximum Drywell

- Suppression pool water Spray Flow Rate Limit)].

level is below 18 feet (elevation of bottom of internal suppression chamber to dryvell v.scuum breakers less vacuum breaker opening pressure in feet of water).

PC/P-3.1 Shutdown reactor recircula-tion pumps.

PC/P-3.2 Shutdown drywell blowers.

PC/P-3.3 Initiate drywell sprays using only those RHR pumps not required to assure adequate core cooling by continuous operation in the LPCI mode.

JUSTIFICATION OF DIFFERENCE 14.5 is the Suppression Chamber Spray Initiation Pressure. 13' is the elevation of the internal vacuum breakers and is added to ensure they will work to prevent challenging the drywell to torus boundary. Appendix C-8.0 shows the Maximum Drywell Spray Flow Rate is not a concern for BFN. Caution #18 is incorporated into the step. The Drywell Spray Initiation Limit is calculated in Appendix C-9.0.

Page 225 of 378 g,+ 4 e

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PSTG STEP EPG STEP PC/P-4 If suppression chamber pres- PC/P-4 If suppression chamber pressure sure cannot be maintained cannot be maintained below below the Pressure Suppression (the Pressure Suppression Pres-Pressure Limit (see Figure D), sure), EMERGENCY RPV DEPRESSUR-EMERGENCY RX DEPRESSURIZATION IZATION IS REQUIRED.

IS REQUIRED; enter the procedure developed from the Rx Control Guideline at steps RC/L, RC/P, and RC/Q and exe-cute it concurrently with this procedure.

JUSTIFICATION OF DIFFERENCE The BFN specific pressure suppression pressure per Appendix C-12.0 is inserted, t

! Direction is given here to enter the Rx Control Guideline which will direct the operator to take appropriate level control actions and will direct him to the appropriate steps for emergency depressurization of the Rx.

i Page 226 of 378

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, 'PSTG STEP EPG STEP No corresponding step. PC/P-5 If suppression chamber pressure cannot be maintained below (the Primary Containment Design Pressure), RPV FLOODING IS REQUIRED.

JUSTIFICATION OF DIFFERENCE The purpose of this step was to decrease primary containment pressure by flooding subcooled water out a break.,. Subsequent study by the BWROG indicated that the benefit of flow out a break would probably be accomplished without any effort 52n the cart of the operators and that flooding the reactor would needlessly add water to the containment. Therefore, this step was dropped.

Page 227 of 378

PSTG STEP EPG STEE <

PC/P-5 If suppression chamber pres- PC/P-7 If suppression chamber l#22l sure, exceeds 55 psig (Primary pressure exceeds the Containment Pressure Limit), Primary Containment Pressure then irrespective of the off- Limit, vent the primary contain-site radioactivity release ment in accordance with (proce-rate, vent the primary con- dure for containment venting]

tainment, defeating isolation to reduce and maintain pressure interlocks if necessary, to below the Primary Containment reduce and maintain pressure Pressur Limit.

below 55 psig (Primary Con-tainment Pressure Limit) as follows:

PC/P-5.1 If suppression pool water level is below 20 ft.

(elevation of the bottom of the suppression chamber vent), vent the suppression chamber. .

PC/P-5.2 If suppression pool water is above 20 ft. (elevation of bottom of the suppres-sion chamber vent) or if the suppression chamber cannot be vented, vent the drywell.

JUSTIFICATION OF DIFFERENCE The change in order of steps is discussed in the following deviation.

Caution 22 is incorporated into the step. 55 psig is the primary containment pressure limit, based on MSRV operability. Appendix B for EPGs state:

"Containment failure may follow if suppression chamber pressure exceeds the Primary Containment Pressure Limit. At this point venting the containment is the only mechanism which remains to prevent an uncontrolled, unpredictable breach of primary containment integrity and release of radioactivity to the environment.

Although venting will probably result in the release of some radioactivity to the environment, this is preferable to containment failure whereby adequate core cooling is also lost and radioactivity is released with no control whatsoever".

Page 228 of 378 l

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Icplicit in tho step then is venting regardiscs of offsite rcdiocctivity relesso rate. Development of the Primary Containment Pressure Limit dictates the vent paths avsilable to lower containment pressure because vent operability and capability to remove decay heat are mutually dependent. Employing the vent path from the suppression chamber is attempted first in order to maintain containment function and maximize the effect of pool scrubbing. This will help limit the release of radioactivity to areas outside the primary containment. As a last resort, the operator is directed to vent containment using the drywell vent path but only if the suppression chamber vent penetration is submerged or all reasonable attempts at establishing the suppression chamber vent path have failed.

Since the design basis accidents predict a maximum drywell pressure of 49.6 psig, this step does not conflict with the assumptions in the FSAR.

Addressing the steps, the Primary Containment Pressure Limit is 55 psig and is based on MSRV operability.

20 ft, is well below the location of the torus vent (31 ft.) but is the maximum suppression pool level that can be read using existing control room instrumentation. Utilizing this lower limit makes our guideline more conservative than the EPG by providing a larger margin to the torus vent.

The Drywell Spray Initiation Pressure limit is calculated in Appendix C-9.0, Appendix C-8.0 shows the drywell spray flow rate limit is not applicable to BFN.

18 feet is the elevation of the bottom of the drywell to torus internal vacuum breakers and assures the vacuum breakers will work to protect the dryvell/ torus boundary integrity.

Page 229 of 378

PSTG STEP EPG STEP PC/P-6 If suppression chamber pres- 26/P-6 If suppression chamber pressure sure.cannot be maintained cannot be maintained below the below 55 psig (Primary Con- Primary Containment Pressure tainment Pressure Limit), then Limit, then irrespective of irrespective of whether whether adequate core cooling adequate core cooling is is assured:

assured:

• (If suppression pool water PC/P-6.1 If suppression pool water level is below 24 ft. 6 in.

level is below 20 fr. (ele- (elevation of suppression vation of suppression pool. pool spray nozzles)], initiate spray nozzles), in'tiate suppression pool sprays.

suppression pool sprays.

If (suppression chamber temp-PC/P-6.2 If the following conditions erature and drywell pressure exist: are below the Drywell Spray Initiation Pressure Limit],

- Suppression chamber temperature (shut down recirculation and drywell pressure are with- pumps and dryvell cooling fans in the Drywell Spray Initiation and] initiate dryvell sprays limit (see Figure C) AHQ (restricting flow rate to less than 720 gpm (Maximum Spray

- Suppression pool water level Flow Rate Limit)].

is below 18 feet (elevation of bottom of internal sup-pression chamber to drywell ,

vacuum breakers less vacuum breaker opening pressure in feet of water)

1. Shut down reactor recircula-tion pumps.

2. Shut down drywell blowers.

3. Initiate drywell sprays.

l Page 230 of 378

JUSTIFICATION OF DIFFERENCE PSTG step PC/P-5 corresponds to EPG step PC/P-7, and preceeds PSTG step PC/P-6 which corresponds to EPG step PC/P-6. The order of the steps in the PSTG is reversed from the order in the EPG. In the PSTG the operator attempts to vent the containment before using sprays irrespective of adequate core cooling. The steps are reversed from the EPG because of a concern for loss of equipment and loss of adequate core cooling due to use of drywell sprays. In the EPGs it was assumed the primary containment pressure limit was the pressure at which the containment would rupture (approximately twice design pressure) if not vented. As an open item from the SER for EPG Rev. 2, the criteria for defining the containment venting pressure needed to be determined. In so doing, it was realized that the MSRVs and the containment 9ents would be inoperable at the primary containment rupture pressure. Therefore the actions are taken at approximately design pressure and the drywell spray step irrespective of adequate core cooling is executed only if venting is unsuccessful.

20 ft. level specified for the suppression pool spray nozzles is somewhat below the actual nozzle location (26 ft. 10 in.). 20 :'t. is the maximum level that can be read on existing control room instrumentation. This additional margin makes our guideline mora conservative than the generic EPGs by further restricting the region in which suppression pool sprays can be used.

Page 231 of 378

PSTG STEP EPG STEP SP/L-1 Maintain suppression pool SP/L-1 Maintain suppression l#8. #91 water level between -1 in. pool water level (Maximum Suppression Pool between (12 ft. 6 in. (maximum Water Level LCO) and -6.25 in. suppression pool water level (Minimum Suppression Pool LCO)] and (12 ft. 2 in. (min-Water Level LCO). Instruct imum suppression pool water Chemistry to saaple the level LCO)]. Refer to (sampling suppression pool prior to procedure] prior,to discharging discharging water from the water. (Suppression pool make-suppression pool, up may be augmented by SPMS).

JUSTIFICATION OF DIFFERENCE The plant specific high and low torus water level LCO setpoints are incorporated.

Caution #8 and 9 are omitted here. See discussion in the ' caution' section of this document for the appropriate justification. Reference to the SPMS is deleted since that system .s not applicable to Browns Ferry.

1 Page 232 of 378

PSTG STEP EPG STEP No corresponding step. If SPMS has been initiated, maintain suppression pool water level between (23 ft. 9 in. (SPMS initiation set--

point plus suppression pool water level increase which results from SPMS oper-ation)) and (19 ft. 11 in. (minimum suppression pool water level LCO).

JUSTIFICATION OF DIFFERENCE

, BFN does not have an SPMS; therefore, the step is not applicable and is omitted.

s Page 233 of 378

PSTG STEP EPG STEP SP/L-1.1 If suppression pool water If suppression pool water level cannot level cannot be maintained be maintained above (12 ft. 2 in.

above -6.25 in. (Minimum (minimum suppression pool water level Suppression Pool Water LCO)] execute (Step SP/L-2].

Level LCO), execute step SP/L-2.

ei JUSTIFICATION OF DIFFERENCE The BPN plant specific values have been inserted.

Page 234 of 378 e

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E31Q,1IEE EPG STEP SP/L-1.2 If suppression pool water IF suppression pool water level cannot level cannot be maintained be maintained below (12 ft. 6 in.

below -1 in. (Maximum Sup- (maximum suppression pool water LCO)]

ression Pool Water Level ((23 ft. 9 in. (SPMS initiation set-LCO), execute step SP/L-3. point plus suppression pool water level increase which results from SPMS op-eration)) if SPMS has been initiated),

execute (Step SP/L-3].

JUSTIFICATION OF DIFFERENCE Statement addressing SPMS is omitted since BFN does not have an SPMS. The BFN specific numbers are inserted.

Page 235 of 378

PSTG STEP EPG STEP SP/L-2 Suppression pool water level SP/L-2 SUPPRESSION POOL WATER LEVEL below -6.25 in. (Minimum BELOW (12 ft. 2 in. (minimum Suppression Pool Water Level suppression pool water level LCO) LCO)]

Execute steps SP/L-2.1 and

-SP/L-2.2 concurrently.

JUSTIT' 'ATION OF DIFFERENCE l

BFN specific values are inserted. An override is added to the PSTG to execute the

! following two steps concurrently. PSTG step SP/L-2.2 has been added (no corresponding step in Revision 3 of the EPGs) and since the correct sequence of the steps will depend on the event, on override must be added to account for all events.

Page 236 of 378

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L PSTG STEP EPG STEP RWCU (recirculation mode) only if no boron has been injected into the Rx.

RTFT and RTPT drains Other steam driven c:;uipment such as steam seals, SJAEs, and off gas _preheaters.

JUSTIFICATION OF DIFFERENCE 5.5 feet is the elevation of the top of the T-quenchers at BTN. Caution 15 is implemented in the recommended opening sequence.

Direction for the suction source are provided for HPCI and RCIC as discussed in RC/L-2.

Loss of the continuous SRV pneumatic supply limits the number of times that an SRV can be cycled since pneumatic pressure is required for valve operation. Even though the SRV accumulators contain a reserve pneumatic supply, leakage through in-line valves and fittings may deplete this supply. Thus, subsequent to the loss of the continuous SRV pneumatic supply, there is no assurance as to the number of SRV operating cycles remaining. For these reasons, if SRVs must be used to augment Rx pressure control and if the continuous SRV pneumatic supply is or becomes unavailable, then the SRV should be closed to limit the number of cycles on the valve and conserve pneumatic pressure so that if Emergency Rx Depressurization is subsequently required, the valve will be available for this purpose. If other pressure control systems are not capable of maintaining Rx pressure below the lowest SRV lifting pressure, the SRV will still open when its lifting pressure is reached. A subsequent step, RC/P-3.1, provides the guidance necessary to open SRVs and depressurize with sustained opening should Emergency Rx Depressurization be required or the other systema prove inadequate.

There is no isolation condenser at BTNP.

RWCU (Blowdown mode) can be used if no gross fuel failure is suspected rather than referring to a sampling procedure prior to initiating blowdown as in the EPGs. BFH does not have a sampling procedure for going to blowdown and, therefore, there is no action limit on which to base the decision to blow down or not blow down.

Therefore, the decision on whether or not to blowdown is based on the operators assessment if gross fuel failure has occurred. This decision is based on his assessment of the sequence of events (i.e. have events occurred with the potential to damage fuel) and indications that some fuel failures have occurred such as main steamline radiation levels higher than normal, RPS or PCIS Group 1 trips, etc. If no gross fuel failure is suspected and the operator believes the reactor water contaminants are normal, blowdown via RWCU is permitted. Since RWCU is so poor at reducing pressure, the operator is not expected to use this mode if the SRVs are functioning. Therefore, this acticn is only used in events outside the BFN design bases.

Page 1b3 of 378 y-- _,w. -- -

Cautica 3 centains tho BFN specific numbers. Caution 4 is cdded hers since it is ,

very likely that heat will be added to the torus at this point. ,

RFPT and RFPT drains were added to the list as a viable means of alternate pressure control.

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t PSTG STEP EPG STEP a

RC/P-3 When either:

RC/P-3 When either:

- all control rods are in- All control rods are in-serted to or beyond pos- serted beyond position (06 ition 02 (Maximum Sub- (maximum suberitical' banked critical Banked Withdrawal withdrawal position)), or Position), or (280 pounds -(Cold Shutdown

- 669 pounds of boron (Cold Boron Weight)) of boron Shutdown Boron Weight) have been injected into the have been injected into RPV, or the Rx, or The reactor is shutdown and

- the Rx is shutdown and no no boron has been injected boron has been injected into the RPV, into the Rx depressurize the RPV depressurize the Rx and and maintain l#14 #171 maintain cooldova rate below cooldown rate below 100 degrees F per hour (100*F/hr (RPV cooldown (Rx cooldown rate LCO). rate LCO)).

JUSTIFICATION OF DIFFERENCE 9

Caution 14 and 17 are omitted here. See justifications contained in the

' cautions' section of this document.

The following plant specific numbers are inserted:

02 is the maximum suberitical banked withdrawal position for BFN. 669 lbs. is the cold shutdown boron weight. 100*F/hr is the Rx cooldcwn rate LCO.

I Page 185 of 378

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ESTG STEPS EPG STEP RC/P-3.1 If one or more SRVs are No corresponding step.

being used to depressurise the Rx and Drywell Control Air AHQ Control Air become unavailable, depressurize with sustained SRV opening.

F

• me JUSTIFICATION OF DIFFERENCE When SRVs are used to depressurize (i.e., cooldown) the Rx, the operator must be aware of the limited number of open/close cycles available if the "continuous SRV pneumatic supply is or becomes unavailable". The ability to hold open.an SRV is

- in part d3 pendent on the pressure in the SRV pneumatic supply accumulators. To conserve this source, the operator is directed to "depressurize with sustained SRV

- opening" thus avoiding pneumatic supply pressure loss in cycling SRVs. Typically one SRV can discharge the equivalent of about 6-percent rated steam. Decay heat produces less than 3-percent thermal energy (depending on power history, time after shutdown, etc). As a result, cooldown rates more rapid than the LCO vill occur and are permitted by this step. Besides the normal source of SRV pneumatics, any means by which the supply header may be pressurized such that SRVs will. remain operable is considered a "continuous' supply. Any of these alternate means should be interpreted as maintaining the SRV pneumatic header available.

This step in conjunction with step RC/P-2.1 addressing SRVs meets the intent of EPG step RC/P-2 addressing SRVs.

Page 186 of 378 9

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PSTG STEP EPG STEP

1. If suppression pool water level If suppression pool water level cannot cannot be maintained above the be maintained above the Heat Capacity Heat Capacity Level Limit (see Level Limit, EMERGENCY RPV DEPRESSUR-Figure E), EMERGENCY RX DEPRES- IZATION IS REQUIRED enter (procedure SURIZATION IS REQUIRED; enter developed from the RPV Control Guide-the procedure developed from the line) at (Step RC-1] and execute it Rx Control Guideline at steps concurrently with this procedure.

RC/L, RC/P, and RC/Q and execute it concurrently with this proce-dure.

s JUSTIFICATION OF DIFFERENCE Step RC-1 has been incorporated in RC/Q. Therefore, there is effectively no change in the step execution order (see the justification contained at the beginning of section RC/Q).

Page 237 of 378 s..+..-~ . - - - . . . ...n.-. -w- . .- .

4 PSTG STEP EPG STEP SP/L-2.2 Maintain suppression pool No corresponding step.

water level above 12.75 ft.

(elevation of the top of the HPCI exhaust).

1. If suppression pool water level cannot be maintained above 12.75 ft. (elevation of the top of the HPCI exhaust), secure HPCI irrespective of whether adequate core cooling can be assured.

JUSTIFICATION OF DIFFERENCE Operation of the HPCI system with the exhaust line uncovered vill result in rapid pressurization of the suppression chamber, possibly leading to containment failure. Since failure of the containment structure could compromise the integrity of systems which penetrate containment that may, in fact, be maintaining cooling flow to the core, HPCI must be secured irrespective of providing adequate core cooling. There is no guarantee that, once containment fails, continued adequate core cooling vill be provided.

l l

l Page 238 of 378 l

PSTG STEP EPG STEP

1. If suppression pool water level If suppression pool water cannot be maintained below the cannot be maintained below l#13. #141 Suppression Pool Load Limit (See the Suppression Pool Load Figure G), maintain Rx pressure Limit, maintain RPV pressure below the below the limit in accordance with limit.

the procedt s developed from RC/P; enter the dure developed from tb trol Guideline at steps and RC/Q and execut rently with this procedu.

s JUSTIFICATION OF DIFFERENCE RC/P provides directions for controlling reactor pressure. It is appropriate to enter RC/L and RC/Q at the same time because of pressure effects on the other two variables. Caution 13 and 14 are omitted here. See the ' caution' section of this document for the appropriate justifications.

Page 240 of 378

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PSTG STEP EPG STEP SP/L-3 Suppression pool water level SP/L-3 SUPPRESSION POOL WATER LEVEL above -1 in. (Maximum AB0VE [12 ft. 6 in. (maximum Suppression Pool Water Level suppression pool water level LCO) LCO)} ((23 ft. 9 in. (SPMS init-iation setpoint plus suppression pool water level increase which results from SPMS operation))

if SPMS has been initiated)

JUSTIFICATION OF DIFFERENCE

~

BFN specific limits are inserted. Reference to SPMS (which BFN does not have) is deleted. , ,

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i Page 239 of 378 9

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PSTG STEP EPG STEP

3. If suppression pool water level If suppression pool water level and RPV and Rx pressure cannot be restored pressure cannot be restored and main-and maintained below the Suppres- tained below the Suppression Pool Load sion Pool Load Limit (see Figure Limit, EMERGENCY RPV DEPRESSURIZATION G), EMERGENCY RX DEPRESSURIZATION IS REQUIRED; enter (procedure developed IS REQUIRED. from the RPV Control Guideline) at (step RC-1] and execute it concurrently with this procedure.

JUSTIFICATION OF DIFFERELLQE Rx Control was entered in part 1 of step 3.1 and is not necessary to re-enter.

Actions specified in RC/P will. direct the operator to the appropriate point in the procedure te carry out Emergency Depressurization actions.

The Suppression Pool Load Limit curve shown in Figure G, is not the same ss the curve calculated in Appendix C-4.0. The curve shown in Figure G reflects an upper limit cr suppression pool level indication of 20 ft. This makes the curve more conservative by adding additional margin to reaching the maximum allowable stress on the limiting component.

Page 241 of 378

PSTG STEP EPG STEP ,

If while executing steps SP/L-3.2.1 No corresponding step.

through SP/L-3.2.3:

- Drywell sprays have been initiated and drywell pressure drops below 2.45 psig (high drywell pressure scram setpoint), stop drywell sprays.

JUSTIFTCATION OF DIFFERENCE In the following step, drywell sprays are directed to be used. This override is added to assure the drywell ,is not taken negative relative to atmospheric pressure and thus maintain margin to the drywell negative containment design pressure and to the negative drywell to torus differential pressure. The high drywell pressure scram setpoint is chosen as the action limit to assure for ATWS events that high drywell pressure won't prevent the resetting of RPS.

Page 242 of 378 e -* 87se'e==.', a+ 4.*wm m , , . . .,

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PSTG STEP EPG STEP SP/L-3.2 Before suppression pool SP/L-3.2 Before suppression pool water water level reaches 18 ft. level reat.hes (17 ft. 2 in.

(elevation of bottom of (Maximum Primary Containment suppression chamber to dry- Water Level Limit or elevation well vacuum breakers less of bottom of Mark I internal vacuum breaker opening suppression chamber to drywell pressure in feet of water) vacuum breakers less vacuum but only if adequate core breaker opening pressure in cooling is assured, term- feet of water, whichever is inate injection into the Rx lower)) but only if adequate from sources external to core cooling is assurt-, t e rm-the primary containment inate injection into the RPV except from boron injection from sources extcrnal to the systems and CRD. primary containment except from boron injection systems and CRD.

JUSTIFICATION OF DIFFERENCE BFN specific limits are inserted.

Page 243 of 378

• e , e .

• * . ,+e

PSTG STEP EPG STEP Execute steps SP/L-3.2.2 and No corresponding step.

$P/L-3.2.3 concurrently.

JUSTIFICATION OF DIFFERENCE t

Step is added because the sequence of steps 3.2.2 and 3.2.3 are event dependent.

To address all events (hence, be symptomatic) the steps must be performed concurrently.

Page 245 of 378

• "9'" *

• e> =* = w g me e , ,

"e-r

-r M==--m- - e yw - + -- ty--.. -m ,m, c =q- ,,.w .,y,e,y y -

-pw.,, - - --

PSTG STEP EPG STEP

1. When suppression pool water level 1. When suppression pool l#18l reaches 18 ft. (elevation of water level reaches bottom of suppression chamber to (17 ft. 2 in. (elevation of bottom drywell vacuum breakers less of Mark I internal suppression vacuum breaker opening pressure in chamber to drywell vacuum breakers feet of water) but only if sup- less vacuum breaker opening pressure pression' chamber temperature and in feet of water)] but only if drywell pressure are within the (suppression chamber. temperature and Drywell Spray Initiation Limit drywell pressure are below the (see Figure C): Drywell Spray Initiation Pressure Limit], (shut down recirculation

- Shut down reactor recirculation pumps and drywell cooling fans and]

pumps, initiate drywell sprays (restricting

- Shut down drywell blowers, flow rate to less than 720 gpm

- Initiate drywell sprays using (Maximum Drywell Spray Flow Rate caly those RHk pumps not requir- Limit)].

ed to assure adequate core cooling by continuous operation in the LPCI mode.

JUSTIFICATION OF DIFFERENCE The BFN specific valu.es are inserted. The drywell spray initiation pressure limit is documented in Appendix C-9.0. Appendix C-8.0 shoes the maximum drywell. spray flow rate limit is not limiting for BFN. Caution 18 is incorporated in the step.

Page 244 of 378

==e.g e.e e e em +e -,o.- p.,, e-aee. 9,mgp a .e s. . =g& = . g e =

• PSTG STEP EPG STEP

2. While suppression pool water level 2. If suppression pool l#23l is above 18 ft. (elevation of bottom water level exceeds (17 ft.

of suppression chamber to drywell 2 in. (elevation of bottom of Mark vacuum breakers less vacuum breaker I internal suppression chamber to opening pressure in feet of water), drywell vacuum breakers less vacuum do not initiate but, if initiated breaker opening pressure in feet of previously, continue to operate water)), continue to operate drywell drywell sprays until drywell pressure sprays (below 720 gpm (Maximum Dry-is below 2.45 psig (high drywell well Spray Flow Rate Limit)].

pressure scram setpoint) using only those RHR pumps not required to assure adequate core cooling by continuous operation in the LPCI mode.

3 JUSTIFICATION OF DIFFERENCE The PSIG step incorporates caution #23 into the step, omits the reference to dryvell spray flow rate limit since this is not limiting at Browns Ferry (see Appendix C-8.0), inserts the BFN specific numbers, and adds an action to stop sprays when drywell pressure decreases below the high drywell pressure scram setpoint. This is done to prevent the drywell from exceeding its design negative pressure capability due to the convective cooling action of the sprays. The high drywell pressure scram setpoint is chosen so that the scram will not be prevented from being reset in the event of an ATWS. Caution #18 is also incorporated in this step specifying the priority of use of RHR pumps.

Page 246 of 378

PSTG STEP EPG STEP

3. When primary containment water 3. When primary containment water level level reaches 108 ft. (Maximum reaches-(104 ft. (Maximum Primary Primary Containment Water Level Containment Water Level Limit)],

Limit), stop injection into the terminate injection into the RPV Rx from sources external to the from sources external'to the primary containment irrespective primary containment irrespective of of whether adequate core cooling whether adequate core cooling is is assured, assured.

JUSTIFICATION OF DIFFERENCE The Maximum Primary Containment Water Level Limit for BFN is calculated in Appendix C-16.0 and inserted in this step.

Page 247 of 378 S

e e& *- t , ,

y-4yy - - ,, - - - - = a-w --'--w-***~r-P'"*r--T'-" -W" " ' ' " ' * " " ' "" " ' '*'#~"" " ' -'~ -

SECONDARY C0!iTAIIOiENT COIITROL GUIDELIITE

(

i Page 248 of 378 4 s=w@ W 9# 44 g , , , .

PSTG STEP EPG STEP ENTRY CONDITIONS ENTRY CONDITIONS The entry conditions for this guide- The entry conditions for this guideline line are any of the following sie Ony of the following secondary secondary containment conditions: containment conditions:

- Differential pressure at or above -Differential pressure at or above 0 in of water 0 in, of water

- An area temperature above the An area temperature above the max-maximum normal operating temper- imum normal operating temperature ature

• An HVAC cooler differential temper-

- A Reactor or Refuel Zone ventila- ature above the maximum normal ation exhaust radiation level operating differential temperature above the maximum normal operating radiation level An HVAC exhaust radiation level above the maximum normal operating

- An area radiation level above the radiation level maximum normal operating radiation level An area radiation level above the maximum normal operating radiation

- A floor drain sump water level level above the maximum normal operating water level A floor drain sump water level above the maximum normal operating o

- An area water level above the water level maximun normal operating water level An area water level above the maximum normal operating water level e

JUSTIFICATION OF DIFFERENCE The entry conditions based on high area temperatures and high HVAC cooler differential tempertures are both used to indicate a steam leak in an area.

Browns Ferry does not have a means of measuring ventilation system cooler differential. We feel that the installed steam leak detection system is sufficient to provide adequate indication of any high area temperatures due to steam leakage. Therefore, the entry condition pertaining to high HVAC cooler differential temperatures is deleted.

Page 249 of 378

PSTG STEP EPG STEP If while executing steps FC/T-1 thru If while executing the following steps SC/T-4: secondary containment HVAC exhaust radiation level exceeds (20 mr/hr-

- Reactor zone ventilation exhaust (secondary containment HVAC isolation radiation level exceeds 72 or/hr setpoint)):

(isolation setpoint), confirm or manually initiate isolation of Confirm or manually initiate isola-reactor zone and refuel zone vent- tion of secondary containment HVAC, 11ation, and confirm initiation of and or manually initiate SGTS. ,

Confirm initiation of or manually

- Refuel zone ventilation exhaust initiate SBGT [only when the space radiation level exceeds 67 mr/hr being evacuated is below 212*F).

(isolation setpoint), confirm or manually initiate isolation of refuel zone ventilation, and confirm initiation of or manually initiate SGTS.

I JUSTIFICATION OF DIFFERENCE Secondary containment HVAC at BFN. consists of the Reactor Building HVAC and Refuel Floor HVAC. 72 mr/hr is the , Reactor Building HVAC isolation setpoint. 67 mr/hr is the Refuel Floor HVAC isolation setpoint.

(

1 Page 250 of 378 a+ we

PSTG STEP EPG STEP If while exe'cuting steps SC/T-1 If while executing the following steps:

through SC/T-4:

Secondary containment HVAC isolates,

- Reactor zone or refuel zone vent- and, 11ation isolates, and {

Secondary containment HVAC exhaust

- Reactor zone ventilation exhaust radiation level is below (20 mr/hr radiation level is below 72 mr/hr (secondary containment HVAC isola-

[ (isolation setpoint) or refuel tion setpoint)],

l zone ventilation exhaust radiation level is below 67 mr/hr (isolation restart secondary containment l f/24 l setpoint) HVAC.

? l restart reactor zone or refuel zone ventilation, defeating high drywell pressure and low Rx water level isolation interlocks if necessary.

JUSTIFICATION OF DIFFERENCE The appropriate BFN setpoints are inserted. EPG Caution 24 is incorporated into the step.

l l

1 l

l Page 251 of 378

PSTG STEP EPG STEP If Rx building to outside air dif- No corresponding step, ferential pressure is greater than or equal to 0 inches of water, verify running all available reactor zone and refuel zone ventilation or man-ually initiate SGTS.

JUSTIFICATION OF DIFFERENCE This step was added to ensure all,available ventilation systems are operated in an attempt to re-establish the appropriate Rx building to outside air differential pressure.

Page 252 of 378 9

9 9 4 + g. e

PSTG STEP EPG STEP No corresponding step. SC/T-1 Operate available area coolers.

I l

l JUSTIFICATION OF DIFFERENCE An BFN, the normal mechanism for cooling secondary containment is reactor building and refueling floor HVAC. The only installed area coolers are located in the RHR and Core Spray pump rooms. These coolers auto start on either: 1) associated RHR or Core Spray pump start or, 2) room high temperature (90*F). There is no way to manually start these coolers. Therefore, the action to operate these coolers is omitted.

Page 253 of 378

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

ESTG STEP EPG STEP SC/T-1 If reactor zone ventilation SC/T-2 If secondary containment HVAC exhaust radiation level is exhaust radiation level is below 72 mr/hr (isolation below (20 mr/hr (secondary setpoint) or refuel zone containment HVAC isolation ventilation exhaust radiation setpoint)], operate available level is below 67 mr/hr secondary containment HVAC.

(isolation setpoint), operate reactor zone or refuel zone ventilation.

JUSTIFICATION OF DIFFERENCE Secondary containment HVAC is divided into reactor building HVAC and refuel floor HVAC. The appropriate BFN s,etpoints are inserted for these ventilation systems.

Page 254 of 378 90 h' * * . * ' *

• 4

• PSTG STEP EPG STEP SC/T-2 When'an area temperature SC/T-3 If any area temperature exceeds exceeds its maximum normal its maximum normal operating operating temperature, iso- temperature, isolate all late all systems that are systems that are discharging discharging into the area into the area except systems except systems required to required to shut down the shut down the reactor, assure reactor, assure adequate core adequate core cooling, or cooling, or suppress a working suppress a fire, fire.

JUSTIFICATION OF DIFFERENCE "When an" is inserted in place of 'lif any", "If" is conventionally used to mean test for a condition and proceed if the condition does not exist. "When" is used to mean wait until the condition exists before proceeding. Based on the action levels in this step and the following steps it is appropriate to wait at this step, then proceed sequentially.

The adjective "working" is dropped from describing a fire because BFN does not use that terminology.

Page 255 of 378 n = e,

• 7.

PSTG STEP EPG STEP Execute steps'SC/T-3 and SC/T-4 No corresponding step.

concurrently.'

JUSTIFICATION OF DIFFERENCE An additional step SC/T-4 has been added and is required to be performed concurrently with SC/T-3 sine,e.the' sequence of required actions will not be the same for all events. The basis for the additional step is discussed with the step SC/T-4.

Page 256 of 378

PSTG STEP EPG STEP SC/T-3 If a primary system is dis- SC/T-4 If primary system is dis-charging into secondary charging into an area, then containment: before any area temperature reaches its maximum safe oper-SC/T-3.1 Before any area ating temperature, enter temperature reaches (procedure developed from the its maximum safe RPV Control Guideline) at operating tempera- (Step RC-1) and execute it ture, enter the concurrently with this proce-procedure developed dure.

from the Reactor Control Guideline at steps RC/L, RC/P and RC/Q and execute it con-currently with this procedure.

JUSTIFICATION OF DIFFERENCE EPG steps SC/T-4 and SC/T-5 are contained in PSTC steps SC/T-3.1 and SC/T-3.2.

These two steps are both conti,ngent on a primary system discharging into secondary containment and are thus contained under PSTG step SC/T-3.

EPG Step RC-1 is incorporated into PSTG step RC/Q. Because RC/L, RC/P, and RC/Q are all entered concurrently upon entry into the Reactor Control Guideline, the I action from RC-1 will still be performed upon initial entry into the Reactor Control Guideline.

Page 257 of 378 e

(w* ** .*%e'- '

sa*". p geeem, ,m _,

PSTG STEP EPG STEP SC/T-3.2 When an area temperature SC/T-5 If a primary system is discharg-exceeds its maximum safe ing into an area and an area operating temperature in more temperature exceeds its max-than one area, EMERGENCY RX imum safe operating temperature DEPRESSURIZATION IS REQUIRED. in more than one area, 4

EMERGENCY RPV DEPRESSURIZATION IS REQUIRED.

P

TUSTIFICATION OF DIFFERENCE 4

PSTG step SC/T-3.2 is the second substep of step SC/T-3 and is contingent on a primary system discharging into secendary containment. The logic term "when" replaces "if" in this step because it is appropriate to wait here and test for the condition until this procedure is exited. This will not prevent execution of step SC/T-4 because of the concurrent execution action stated just prior to step SC/T-3.

Page 258 of 378 e are e+ * ' M4 e 4eea 4 + ..-e,g4 e- eus * * * ***$ e en *

• I PSTG SIEE i EPG STEP SC/T-4 When'an area temperature No corresponding step.

exceeds its maximum safe I operating temperature in more than one area, shut down the reactor in accordance with GOI-100-12 (procedure for shutdown from power and cool down to cold shutdown con-ditions).

\

\

JUSTIFICATION OF DIFFERENCE Irrcapective of the source of increasing secondary containment temperature, it is prudent to commence an orderly reactor shutdown when maximum safe operating values are exceeded in more than one area. When the rise in secondary containment temperature spreads to more than one area, a direct threat exists relative to secondary containment integrity, to equipment located in'the secondary containment, and to continued safe operation of the plant.

Action to scram the reactor is not precluded by the wording of this step.

However, if a primary system is not discharging into the secondary containment, a

. reactor scram would not achieve the desired reduction in area temperature.

Shutting down the reactor in accordance with normal operating procedures is the most appropriate action based ,upon the current status of secondary containment parameters. Should an operator conclude at any time while performing Step SC/T-4 that the high secondary containment temperatures are, in whole or in part, due to a primary system discharge, Step SC/T-3 (being executed concurrently) provides the necessary direction to scram and depressurize the reactor. G0I-100-12 is the normal plant shutdown procedure.

EPG Step RC-1 is incorporated into PSTG step RC/Q. Because RC/L, RC/P, and RC/Q are all entered concurrently upon entry into the Reactor Control Guideline, the action from RC-1 will still be performed upon initial entry into the Reactor Control Guideline.

Page 259 of 378

e PSTG STEP EPG STEP SC/R-1 When an area radiation level SC/R-1 If any area radiation level exceeds its maximum normal exceeds its maximum normal operating radiation level, operating radiation level, isolate all systems that are isolate all systems that are discharging into the area discharging into the area except systems required to except systems required to shutdown the reactor, assure shut down the reactor, assure adequate ~ core cooling, or adequate core cooling, or suppress a fire, suppress a working fire.

l e

e JUSTIFICATION OF DIFFERENCE "When" is used in the PSTG step in place of "If". "If" is conventionally used to check a condition exists and, ,1f not, move to the next step. "When" is used to mean wait for that condition, then take action and proceed to the next step.

Since the following steps will occur sequentially behind SC/R-1 due to the progressive action levels, it is appropriate to wait for the condition at this step before proceeding. The term "working" is dropped from the expression "working fire" since that expression is not used at BFN.

Page 260 of 378 e

s e,+ *e3 -,e < em.e n g a , m. e== =e, e,% = ,

- PSTG' STEP EPG STEP Execute steps SC/R-2 and SC/R-3 No corresponding step.

concurrently, f

JUSTIFICATION OF DIFFERENCE An additional steps SC/R-3 has been added and is required to be performed concurrently with step SC/R-2,since the sequence of required actions will not be the same in all events. The basis for the additional step is discussed with the i step, PSTG step SC/2-3.

Page 261 of 378

- _~ , . . _ , < . . - - - - - , . . . - , . - , . - . , _ , _ . , , . _ _ . - , . . _ , , _ . . . , . _ . . - . . .-~r_ . _ , - . _ . - _,_ - , _ . . , y

PSTG STEP EPG STEP SC/R-2 If a primary system is dis- SC/R-2 If a primary system is dis-charging into secondary charging into an area, then containment: before any area radiation level reaches its maximum safe op-SC/R-2.1 Before any area erating radiation level, enter radiation level [ procedure developed from the reaches its maximum RPV Control Guideline] at safe operating [ Step RC-1] and execute it radiation level, concurrently with this pro-enter the procedure cedure.

developed from the RX Control Guideline at steps RC/L, RC/P, and RC/Q and execute it concurrently with this procedure.

JUSTIFICATION OF DIF'rERENCE EPG steps SC/R-2 and SC/R-3 are contained in PSTG steps SC/R-2.1 and SC/R-2.2.

These two steps are both contingent on a primary system discharging into secondary containment and are thus contained under PSTG step SC/R-2.

EPG step RC-1 is incorporated into PSTG step RC/Q. Because RC/L, RC/P, and RC/Q are all entered concurrently upon entry into the Rx Control Guideline, the action from RC+l will still be performed upon initial entry into the Rx Control Guideline.

Page 262 of 378

.. .ea* . , . e ~..a% . .. . .

. . - ,~.- - . c-p - . , - y - -. , - , - - - - - - + - - -.*Wy--- ,

PSTG STEP EPG STEP SC/R-2.2 When an area radiation SC/R-3 If a primary system is dis-level exceeds its maximum charging into an area and an safe operating radiation area radiation level exceeds level in more than one its maximum safe operating area, EMERGENCY RX DEPRES- radiation level in more than SURIZATION IS REQUIRED. one area, EMERGENCY RPV DEPRESSURIZATION IS REQUIRED.

JUSTIFICATION OF DIFFERENCE PSTG Step SC/R-2.2 is the second substep of step SC/P.-2 and is contingent on a primary system discharging into secondary containment. The logic term "When" replaces "If" in this step because it is appropriate to wait here and test for the condition until this procedure is exited. This will not prevent execution of step SC/R-3 because of the concurrent execution action stated just prior to step SC/R-2.

Page 263 of 378 4

-ei ==a . . . . _

g

PSTG STEP EPG STEP SC/R-3 When an area radiation level No corresponding step.

exceeds its maximum safe operating radiation level in more than one area, shut down the reactor in accor-dance with GOI-100-12 (procedure for shutdown from power and cool down to cold shutdown conditions).

I JUSTIFICATION OF DIFFERENCE Irrespective of the source of the high secondary containment radiation level, it is prudent to commence an orderly reactor shutdown when maximum safe operating values are exceeded in more than one area. Action to scram the reactor is not precluded by the wording of this step. However, if a primary system is not discharging into the secondary containment, a reactor scram would not achieve the desired reduction in area radiation level. Shutting down the reactor in accordance with normal operating procedures is the most appropriate action based upon the current status of secondary containment parameters. Should an operator determine at any time while performing step SC/R-3 that the secondary containment radiation level increase is, in whole or in part, due to a primary system discharge, Step SC/R-2 (being executed concurrently) provides the necessary direction to scram the reactor and depressurize. GOI-100-12 is the normal plant shutdown procedure.

Page 264 of 378

• e s e

1

)

)

l PSTG STEP EPG STEP SC/L-1 When a floor drain sump or SC/L-1 If any floor drain sump or ,

area water level is above area water level is above its i its maximum normal operating maximum normal operating water-water level, operate avail- level, operate available sump able sump pumps to restore pumps to restore and maintain and maintain it below its it below its maximum normal maximum normal operating operating water level.

water level.

JUSTIFICATION OF DIFFERENCE "When" is used in the PSTG step in place of "If". "If" is conventionally used to check a condition exists and, if not, to move to the next step. "When" is used to mean wait for that condition, then take action and proceed to the next steps.

Since the following steps will occur sequentially behind SC/L-1 due to the progressive action levels, it is appropriate to wait for the condition at this step before proceeding.

Page 265 of 378

PSTG STEP EPG STEP Execute steps SC/L-2 and SC/L-3 No corresponding step.

concurrently.

JUSTIFICATION OF DIFFERENCE An additional step SC/L-3 has been added and is required to be performed concurrently with step SC/L-2 since the sequence of required actions will not be the same for all events. The basis for the additional step is discussed with the step, PSTG step SC/L-3.

Page 5.56 of 378 4w e.-*-+ , . . -

x.

PSTG STEZ EPC STEP SC/L-2 If a primary system is dis- SC/L-2 If a primary system is dischar-charging into secondary ging into an area, then before containment: any floor drain sump or area water level reaches its maximum SC/L-2.1 Before any area water safe operating water level, level reaches its enter (procedure developed from maximum safe op :ra- the RPV Control Guideline) at ting water 16cel, (Step RC-1] and -execute it enter the procedure concurrently with this developed from the procedure.

Rr Control Guideline at steps RC/L, RC/P, and RC/Q and execute it concurrently with the procedure ,

developed from this guideline.

t JUSTIFICATION OF DIFFERENCE EPG steps SC/L-2 and SC/L-3 are contained in PSTG steps SC/L-2.1 and SC/L-2.2 .

These two steps are both contingent on a primary system discharging into secondary containment and are thus contained under PSTG step SC/L-2.

EPG step RC-1 is incorporated into PSTG step RC/Q. Because KC/L, RC/P, and RC/Q are all entered concurrently upon entry into the Rx Control Guideline, the action from RC-1 vill still be performed upon initial entry into the Rx Control Guideline.

The term "floor drain sump" is dropped from the PSTG step because there are not any maximum safe operating levels attributable to floor drain sumps.

Page 267 of 378

-+=D*+- = , one a ei --yg. e . , , , , , , , , , , , , , ,,

g w - - , _ - - -

PSTG STEP EPG STEP SC/L-2.2 When an area water level SC/L-3 If a primary ayctem is dischar-exceeds it maximum safe ging into an area and a floor operating water level in drain sump or area water level more than one area, exceeds its maximum safe EMERGENCY RX DEPRESSURIZA- operating water level in more TION IS REQUIRED. than one area, EMERGENCY RPV DEPRESSURIZATION IS REQUIRED.

JUSTIFICATION OF DIFFERENCE PSTG step SC/L-2.2 is the second substep of SC/L-2 and is contingent on a primary system discharging into secondary containment. The logic term "When" replaces "If" in this step because it is appropriate to wait here and test for tue condition until this pr1cedure is exited. This will not prevent execution of step SC/L-3 because of the concurrent execution action stated just prior to step SC/L-2.

The term "floor drain sump" is dropped from th JTG step because t: tere are no maximum safe operating levels attributaole to floor drain sumps at BFN.

Page 268 of 378

PSTG STEP EPG STEP SC/L-3 When an area water level No corresponding step, exceeds its maximum safe operating water level in more.

than one area, shut down the reactor in accordance with GOI-100-12 (procedure for shutdown from power and cool down to cold shutdown con-disions).

JUSTIFICATION OF DIFFERENCE When the accumulation of water can no longer be confined to one secondary containment area, a direct threat exists relative to secondary containment '

integrity, to equipment located in the secondary containment, and to continued safe operation of the plant. Irrespective of the source of water, it is prudent to commence an orderly reactor shutdown.

Action to scram the reactor is not precluded by the wording of this step.

However, if a primary system is not discharging into the secondary containment, a reactor scram would not achieve the desired reduction in area water level.

Shutting down the reactor in accordance with normal operating procedures is the most appropraite action based upon the current status of secondary containment parameters. Should an operator determine at any time while performing Step SC/L-3 that the secondary containment water level increase is, in whole or in part, due to a primary system discharge, step SC/L-2 (being executed concurrently) provides the necessary direction to scram the reactor and depressurize.

GOI-100-12 is the normal plant shutdown procedure.

Page 269 of 378 9

4'8 P #**' s e e- e e u 4 4e i *

• ee e e 4e = * - . .

PSTG STEP TABuE 1 -

OPERATING VALUES OF SECONDARY CONTAINMENT PARAMETERS MAX NORMAL MAX SAFE SECONDARY CONTATNMENT PARAMETER OPERATING OPERATING VALUE VALUE AREA TEMPERATURE DEGREES F DEGREES F HPCI room, El. 519 175 290 NW corner room, El. 519 175 295 NE corner room, El. 519 150 180 SW corner room, El. 519 160 -185 SE corner room, El. 519 160 265 Torus area, El. 519 (west) 175 280 Torus area, El. 519 (east) 160 280 Main Steam Vault, El. 565 160 300 Drywell Access, El. 565 160 205 General area, 21. 593 160 205 RWCU Pump room 2A, El. 593 120 220

, RWCU Pump room 2B, El. 593 120 220 RWCU Heat Exchanger room, El. 593 120 215 General area, El. 621 160 215 Page 270 of 378 4

es i e b

• es e g g - % g a e. . . . , , . . .we < . . - *-

er e e ++ - . *

-.p-, - - - - .

7ABLE 1 OPERATING VALUES OF SECONDARY CONTAINMENT PIRAMETERS MAX NORMAL MAX SAFE SECONDARY CONTAINMENT PARAMETER OPERATING OPERATING VALUE VALUE _

VENTILATION EXH/ '3T RADIATION LEVEL MR/HR Reactor Zone 72 N/A Refuel Zone 67 N/A AREA RADIATION LEVEL MR/HR MR/HR HPCI . om, El. 519 (HPCI in standby) 10 1000 HPCI room, El. 519 (HPCI running) 100 1000 NW corner room, El. 519 10 1000 NE corner room, El. 519 10 1000 SW corner room, El. 519 80 1000 SE corner room, El. 519 80 1000

-Torus area, El. 519 30 1000 CRD-HCU area west, El. 565 100 1000 CRD-HCU area east, El. 565 100 1000 TIP room, El. 565 (TIPS shielded) 1000 3000 TIP room, El. 565 (TIPS unshielded) 10,000 100,000 TIF drive, El. 565 10 1000 RWCU area north, El. 593 10 1000 RWCU area south, El. 593 10 1000 RWCU area, El. 621 10 1000 South side, El. 639 10 1000 Fuel Storage Pool Area, El. 664 10 1000 Service Floor Area, El. 664 10 1000 New Fuel Storage, El. 664 10 1000 Page 271 of 378 G

> gn e De@gt ** ' e e- g 4 ,, 4. , g*<e*^ * * **- m

TABLE l' OPERATING VALUES OF SECONDARY CONTAINMENT PARAMETERS MAX NORMAL MAX SAFE SECONDARY CONTAINMENT PARAMETER OPERATING OPERATING VALUE VALUE FLOOR DRAIN SUMP WATER LEVEL INCHES Sump 2A (SW corner) 66 N/A Sump 2B (SE corner) 66 N/A AREA WATER LEVEL INCHES INCHES NW corner room, El. 519 2 22 NE corner room, El. 519 2 21 SW corner room, El. 519 2 21 SE corner room, El. 519 2 21 HPCI room, El. 519 2 20 Torus area, El. 519 2 22 4

Page 272 of 378 4

-N

• • • MP = se - e.. . me.,#e - e, m. . -e .

EPG STEP TABLE 1 OPERATING VALUES OF SECONDARY CONTA.TNMENT PARAMETERS-1 1 SECONDARY: CONTAINMENT ALARM MAXIMUM NORMAL MAXIMUM SAFE PARAMETER / LOCATION OPERATING VALUE OPERATING VALUE

• Differential pressure (in. vater) (in. water) (in. water)

- Reactor Building /outside air ---- -----------

l l

- Refuel Floor /outside air ----- -- 0 --

• Area temperature .(*Il L'Il .(

• E.).

- RWCU "A" pump room 158' ----- -- 130 --- -

- RWCU "B" pump room 158' ---- - 130 ----

- RWCU Rx room 158 ' at Ex. -------- 130 --

- RWCU Rx room 158' disch-H.W. ---- 130 - - -

- RWCU phase sep room 158' --- - - 130 -- --

- RWCU holding pump room 185 - --- 130 ----------

1 I

- NE Diagonal --- --

---

175 -- -

- SE Diagonal ------------------ -- 175 ----------

l l

- HPCI ro om , a r e a A --------------- 17 5 --- -

- HPCI room, area B ------------------- 175 -----

- HPCI room, area C ------- --- 175 ----------

1 I

- Torus room, vestwall ---------- 200 -- =-

- Torus room, eastwall ---- - 200 --- --

- Torus room, northvall ---------- - 200 -----

- Torus room, southwall -- -

--- 200 l

- Main steam tunnel -- - ---- 160 -- ---

1 i

- S3, Reactor 130 elev., area A 200

- SE, Reactor 130 elev., area B ------- 200 l l

- NW Diagonal, area A --- ----- - 200 ----------

- NW Diagonal, area B ==----------- 200 ----------

- NW Diagonal, area C ------------- 200 ----------

1 I (SC-5) REV. 3 1 Typical values not available.

I Page 273 of 378

• • --g ,

EPG STEP TABLE 1 OPERATING VALUES OF SECONDARY CONTAINMENT PARAMETERS 1 1 SECOIDARY-CONTAINMENT ALARM MAXIMUM NORMAL MAXIMUM SAFE PARAMETER / LOCATION OPERATING VALUE OPERATING VALUE

• HVAC cooler differential temperature (*F) (*F) (*F)

- RWCU "A" Pump Room ------ 7 5 - - - - -

- RWCU "B" Pump Room l 75 l

- RWCU Rx Room 158' at Hxs ------ 75 --------

- RWCU Ex Room 158' disch to Hotwell --- 75 -----------

- RWCU phase separator room 158' - 75 --

- RWCU holding pump room 185' ---- 75 -

1 I

- NE Diagonal ---- -----------50------- -

- SE Diagonal ----

-- 50 --

1 I

- HPCI room, Cooler A 40 -----------

- HPCI room, Cooler B ---------- ---- 40 -

1 I

- Torus room, NW --- ----

40 -

- Torts room, West --- --

40 ---- -

I l

- Torus room, NW -

---

40 -----------

- Torus room, West ---------------- 40 -

l

- Torus room, NW -- ------- 40 ---- -

- torus room, West -------- ------ 40 -----------

1 I

- Torus room, NW ---------

-- 40 --- - - -

- i'orus room, West -- --------- 40 ---

l I

- Main Steam Tunnel, Cooler A -- ---- 70

- Main Steam Tunnel, Cooler B -- = -- 7 0 (SC-5) REV. 3 1 Typical vtlues not available.

Page 274 of 378 e

-me.

i EPG STEP TABLE 1 OPERATING VALUES OF SECONDARY CONTAINMENT PARAMETERS 1 1 SECONDARY CONTAINMENT ALARM MAXIMUM NORMAL MAXIMUM SAFE PARAMETER / LOCATION OPERATING VALUE OPERATING VALUE HVAC exhaust radiation level above (mr/hr) (mr/hr) (mr/hr)

- Reactor Building --- 20 -----------

1 I

- Refuel Floor ---- --------------- 20 -------

Area radiation level

- 158' Southeast Area -

-- 15 --

- 158' Northeast Area - --

---

15 --- -

- 158' Northwest Area ------- -- 15 - ------

- 130' Northeast Area ----------- --- 15 -----------

- 130' Southeast Area --- -

---

15

- Decontamination Pump & Equip. Room---- 20 =- -----

- South CRD Hydraulic Units ------- -- 15 -----------

- Spent Fuel Pool Passageway - -- 15 -------

- 185' Operating Floor ------------- 15 -----------

- 185' Sample Panel Area -

15 ------

- CRD Repair Area ------ -----

- 185' RWCU Control Panel Area --------- 15 -------

- RCIC Equipment Area ----------- 20 ------ --

- CRD Pump Room SW -

20 - ---

- RHR & Core Spray Room Northeast 20 --

- RHR & Core Spray Room Southeast -- 20

- Fuel Pool Demin Panel Area - - - 20 ----

(SC-5) REV. 3 1 Typical values not available.

Page 275 of 378 M & 9-me s ee we e

EPG STEP TABLE 1 OPERATING VALUES OF SECONDARY CONTAINMENT PARAMETERS 1 1 SECONDARY CONTAINMENT ALARM MAXIMUM NORMAL MAXIMUM SAFE PARAMETER / LOCATION OPERATING VALUE OPERATING VALUE

' Floor drain sump water level (in.) (in.) (in.)

. - Sump A (S .E. Diagonal) ------ 47 -----------

l l

- Sump B ( S .W . D i a gona l ) ------------ 5 2 --------

1

• Area water level (in.) (in.) (in.)

- CRD Compartment - - - - - - - - 7 ----

- RCIC Compartment - 7 - - - - - - -

- RB NE Corner RM - - - - - - - - - - -

7

- RB SE Corner RM - - - - - - - 7-

- HPCI Compartment - - - - - - - - - - - - - - 7 --

- Torus Compartment IN ,

7 -

- Torus Compartment NE - - - - - - -

7 ----- --

- Torus Compartment SE -- - - -

7---------

- Tours Compartment SW ---------- ---

7 (SC-5) REV. 3 1 Typical values not available.

Page 276 ot' 378

JUSTIFICATION _QF DIFFERENCE The alarm category of'the EPG table is dropped from the PSTGs because no PSTG actions are based on those alarm setpoints. The values for HVAC cooler differential temperature are omitted because BFN does not measure or have a means of measuring HVAC cooler differential temperatures. The appropriate areas, maximum normal operating values, and maximum safe operating values for BFN are inserted in the tables. The values for differential pressure are also omitted from the table because no actions are based on these setpoints. A detailed description of the basis for these setpoints is contained in Appendix B to the PSTGs.

4 Page 277 of 378

RADI0 ACTIVITY RELEASE CONTROL GUIDELINE Page 278 of 378

PSTG STEP EPG STEP ENTRY CONDITIONS ENTRY CONDITIONS The entry condition for this guide- The entry condition for this guideline

.line ist ist

- Offsite radioactivity release Offsite radioactivity release rate rate above 140 Ci/sec (release above (3 Ci/sec (release rate.which rate which requires an Alert). requires an Alert)).

1 JUSTIFICATION OF DIFFERENCE The BFN specific action level has been inserted. 140 Ci/see from the stack is the instantaneous release rate which requires an Alert. .

L Page 279 of 378

. . _ . . . . . . ~ . . , . . . . _ _ . . . _ . . . . . _ ,, . . , ,

r PSTG STEP EPG STEP OPERATOR ACTIONS No corresponding step.

If while executing steps RR-1 and RR-2 turbine building ventilation is shutdown, restart turbine building ventilation.

JUSTIFICATION OF DIFFERENCE Continued personnel access to the turbine building may be essential for responding to emergencies or transients which may degrade into emergencies. The turbine building i's not an air-tight structure, and radioactivity release inside the turbine building would not only limit personnel access, but would eventually lead to an unmonitored ground level release. Operation of turbine building ventilation preserves turbine building accessability, and assures that radioactivity in turbine building areas is discharged through an elevated, monitored release point.

Page 280 of 378 sy- **eM N *9* **+ "M4 t-= m . .go. n m-*s e s &q,g ee.g e e m4 e o =e, ,e e

PSTG STEP EPG STEP RR-2 When any of the following RR-2 If offsite radioactivity release conditions exist: rate approaches or exceeds (91 Ci/sec (release rate which Offsite radioactivity release requires a General Emergency)]

rate approaches or exceeds and a primary system is dis-20,000 C1/see

~

charging into an area outside OR the primary and secondary con-Whole body dose at or beyond tainments, EMERGENCY RPV site boundary is at.or above DEPRESSURIZATION IS REQUIRED; 1000 mr/hr enter (procedure developed from OR the RPV Control Guideline] at Thyroid dose at or beyond site (Step RC-1] and execute it con-boundary is at or above currently with this procedure.

5000 mr/hr OR Activity at or beyond site boundary is at or above 1.46 x 10-6 microcuries per cubic centimeter (uci/cc) for I-131 equivalent but only if a primary system is discharging into an area outside the primary and secon-dary containments, EMERGENCY RX DEPRESSURIZATION IS REQUIRED; enter the procedure dev9l oped from the Rx Control Guideline at steps RC/L, RC/P, and C2 and execute it con-currently with this procedure.

JUSTIFICATION OF DIFFERENCE

'It' is replaced by 'when'. 'And' is replaced by 'but only if'. If implies test for a condition and if the condition does not exist to proceed through the procedure. When implies to monitor for and wait for the condition. It is more important to wait at this point in the procedure than to continue. 'And' is replaced with stronger language 'but only if'. In other words, the action is not tcken unless both conditions exist. Action to scram the reactor and depressurize is not appropriate (although it is not precluded) if a system is not discharging cutside primary and secondary containments.

t

[

Page 281 of 378

l i

l CollTINGENCIES e

J Page 282 of 378 4

4e an g e * ** = + 9gwe- g A.-- m. . ,w., , .%g , = , e **=A- -e.*

• PSTG STEP EPG STEP CONTINGENCY #1 CONTINGENCY #1 ALTERNATE LEVEL CONTROL LEVEL RESTORATION If while executing steps Cl-1 If while executing the following steps:

through Cl-8:

Boron Injection is required, enter

- Any control rod is not inserted to (procedure developed from or beyond position 02 (haximum CONTINGENCY #7].

Suberitical Banked Withdrawal Position), enter the procedure

• RPV vater level cannot be developed from CONTINGENCY 5. determined, RPV FLOODING IS REQUIRED; enter (procedure

- Rx water level cannot be developed from contingency #6].

determined, enter the procedure developed from CONTINGENCY 2.

• RPV Flooding is required, enter (procedure developed from CONTINGENCY #6].

JUSTIFICATION OF DIFFERENCE The condition for transferring level control is changed from a flag indicating several conditions (Boron Injection required) to a symptom (any control rod not inserted to or beyond the Maximum Suberitical Banked Withdrawal Position).

Positive confirmation that the Rx will remain shutdown under all conditions is best obtained by determining that all rods are inserted beyond the Maximum Suberitical Banked Withdrawal Position. If any possibility exists that the Rx may not always remain shutdown on control rod insertion alone, the actions required for control of Rx water level differ from those outlined in the Rx Control Guideline. The Rx water level control actions that are appropriate under this condition are specified in Contingency 5, Level / Power Control.

In the conditional statement box at the beginning of Contingency 1, the direction is to enter C2 if flooding is required. This is a more efficient method of directing flooding actions than is used in the EPGs. Since flooding is performed at low pressure, Emergency Depressurization is required before Rx flooding. The PSTG therefore, shifts procedural control directly to Contingency 2 instead of relying on RC/P to direct the operator to go to C2 if Rx flooding is required.

There is no PSTG bullet corresponding to the third built in the EPGs. This is because the only condition in the PSTG requiring flooding is loss of level indication. This condition is covered by the second bullet, therefore there is no need for the third bullet.

Page 283 of 378 c . .

. l ESIC STEP EPG STEP No corresponding step Cl-1 Initiate IC.

JUSTIFICATION OF DIFFERENCE BFN does not have an isolation condenser, therefore the step is not applicable.

Page 284 of 378

i l PSTG STEP E!illE E

Ci-1 Line up for injection, start Cl-2 Line up for injection and start f pumps, and irrespective of pumps in 2 or more of the L pump NPSH limits, increase following injection subsystems:

injection flow to the maximum with two or more of the -

Condensate following injection subsystems: - HPCS

- LPCI-A Condensate - LPCI-B

- RHR (LPCI mode) System I, - LPCI-C placing the applicable RHRSW - LPCS .1 pump (s) in service as soon -

LPCS-B as possible.

- RHR (LPCI mode) System II, placing the applicable RHRSW pump (s) in service as soon as possible.

- CS System I

- CS System II JUSTIFICATION OF DIFFERENCE The PSTG provides additional directions to inject irrespective of NPSH limits and to increase injection flow to the maximum. Entry into contingency 1 is made when Rx level cannot be maintained above the top of active fuel.

Unlike use of the motor-driven ECCS pumps in step RC/L-2, Contingency #1 actions are carried out even if NPSH limits may be exceeded. Immediate and catastrophic system failure is not expected should operation beyond these limits be required.

Rather, degraded system or pump performance could occur after prolonged operation under these conditions. The undesirable consequence of uncovering the core and losing adequate core cooling outweigh the risk of equipment damage which could

, result if NPSH limits are exceeded.

By increasing injection flow to the maximum, conditions are established whereby, as soon as RPV pressure drops below the system injection pressure, flow will be delivered to the RPV in the quickest possible time. This promotes rapid recovery of RPV water level following which actions can be performed to control injection to maintain a specified RPV water level band.

The EPGs basis document defines the systems as follows: Injection subsystems are defined by the physical separation of components, flowpaths, and injection points. An injection subsystem, as identified in EPG Step Cl-2, is a motor-driven system loop which is independently capable of supplying makeup water to the Rx.

The PSTG systems are selected based on this definition.

Page 285 of 378

. _ . - - _ . .. . _ . ._, . i . . .... _ . - . . . . . _ _ _ . . . . . _ . . _ . . _ ..- . . .

PSTG STEP EPG STEP Cl-2 If less than two of the If less than 2 of the injection injection subsystems can be subsystems can be lined up, commence lined up, commence lining up lining up as many of the following as many of the following alternate injection subsystems as alternate injection subsystems possibles as possible:

RHR service water crosstie

- Condensate transfer pumps to Fire system RHR and CS

• Interconnections with other units 0 to 100 pais, O to 1000 gpm

• ECCS keep-full systems SLC (test tank)

- SLC (test tank-augmented

• SLC (boron tank) by demineralized water head tank)

O to 1400 psig, 23 gpm test tank capacity - 210 gallons demineralized water tank capacity - 30,000 gallons makeup available at 23 spm SLC (boron tank)

O to 1400 psig, 50 gpm storage tank capacity -

4500 gallons RHR crossties to other units , ,

O to 310 psig, O to 5000 spm

- Standby coolant 0 to 160 pais, O to 3500 gpm

- RHR drain pumps

. O to 40 psig, O to 600 gpm PSC head tank pumps 0 to 40 psig, O to 80 gpm

- RCIC (using aux, boiler stm)

, aux. boiler steam pressure 0 to 250 pais Rx pressure O to 350 psig, 600 gpm l

l Page 286 of 3

( .e e e ge-M 9# **S 9- 4 *e e ee pm** . e pge6, ge a g gHehe 9 %9 **

- HPCI (using aux, b311er cta) aux.. boiler steam pressure O to 250 psig Rx pressure O to 350 psig, 5000gpm ,

JUSTIFICATION OF DIFTERENCE The BFN alternate injection subsystems are listed. In addition, the range of Rx pressure against which the systems will inject and the flow capacities across that range are included to provide the operator with a basis for selecting which systems to prioritize setting into service.

i I

4 Page 287 of 378

PSTG STEP. EPG STEP If while executing steps Cl-4 If while executing the following steps:

through Cl-8 The RPV water level trend reverses

- The Rx water level trend reverses or RPV pressure changes region, or Rx pressure changes region, return to (Step Cl-3) .

return to step Cl-3.

RPV water level drops below

(-146 in. (ADS initiation setpoint)), prevent automatic initiation of ADS.

JUSTIFICATION OF DIFFERENCE The EPG step and the PSTG step are both applicable to the remaining steps in their respective contingencies (steps Cl-4 through Cl-8). The second bullet from the EPG is not carried over to the PSTG because ADS automatic initiation is prevented in RC/L just prior to being sent to Contingency 1, Alternate Level Control.

This override is moved up in front of the level / pressure table in the PSTCs because if it followed the table it would be missed by the operators if they followed the prescribed sequence of actions. For example, in the EPGs step Cl-3 directs you to the appropriate step depending on level and pressure. The operators would therefore skip over this override. The PSTG step order prevents this from happening, i

Page 288 of 378 r ... ,

t

PSTG STEP EPG STEP Cl-3 Monitor Ex pressure and Rx Cl-3 Monitor RPV pressure and water water level. Continue in this level. Continue in this procedure procedure at the step indicated at the step indicated in the by logic diagram Cl-3. following table.

RPV PDESSURE REGION l

'" "** ' aa " (425 psig]l (100 psig]2 HIGH INTERMEDIATE LOW l ",

• I jA INCREASING Cl-4 Cl-5 Cl-6

\)/# DECREASING Cl-7 Cl-8

~ "

1 (RPV pressure at which LPCS shutoff

~ " *

>]; head is reached) 2 (HPCI or RCIC low pressure isolation

~

eetpoint, whichever is higher)

~ < . +

~

1 o 4 ,

en4 e, ai e i JUSTIFICATION OF DIFFERENCE A logic diagram is used in the PSTG to accomplish the same intent as EPG table.

320 psig is the reactor pressure at which the core spray shutoff heed is reached (analytical limit). 100 psig is the HPCI low pressure isolation setpoint (which is higher than the RCIC isolation setpoint.

Page 289 of 378 , . . .

PSTG STEP EPG STEP Cl-4 RX WATER LEVEL INCREASING, .. 01-4 RPV WATER LEVEL INCREASING, RPV PRESSURE GREATER THAN 320.

PRE 3SURE HIGH C1-4.1 Enter the procedure Enter (procedure developed froc developed from the Rx the RPV Control Guideline) at Control Guidelines at (Step RC/L].

step RC/L.

JUSTIFICATION OF DIFFERENCE The reactor pressure which defines the cutoff point between Rx pressure high and intermediate is inserted for the PSTG step.

Page 290 of 378 e

~ ~ .- ---.v.-.

PSTG STEP EPG STEP Cl-5 RX WATER LEV 2L INCREASING, RX Cl-5 RPV WATER LEVEL INCREASING, RPV PRESSURE BETWEEN 320 AND 100 PRESSURE INTERMEDIATE PSIG If HPCI and RCIC are not available C1-5.1 If HPCI and RCIC are not and RPV pressure is increasing, operating and Rx pressure EMERGENCY RPV DEPRESSURIZATION is increasing, EMERGENCY IS REQUIRED. When RPV pressure RX DEPRESSURIZATION 19 is dacreasing, enter (procedure REQUIRED. developed from the RPV Control Guideline) at (step RC/L].

1. When Rx pressure is decreasir.g, enter the If HPCI and RCIC are not available procedure developed and RPV pressure is not increas-from the Rx Control ing, enter (procedure developed Guideline at step from the RPV Control Guideline) at RC/L. [ step RC/L].

Cl-5.2 If HPCI and RCIC are not Otherwise, when RPV water level operating and Rx pressure reaches (+12 in. (low level scram is not increasing, enter setpoint)), enter (procedure the procedure developed developed from the RPV Control from the Rx Control Guideline] at (step RC/L).

Guideline at step RC/L.

Cl-5.3 Otherwise, when Rx water level reaches +11 in.

(low level scram set- , .

point), enter the procedure developed from the Rx Control Guideline at step RC/L.

JUSTIFICATION OF DIFFERENCE The Rx pressures which define the intermediate Rx pressure boundaries in step Cl-3 are inserted. The BFN specific low level scram setpoint is inserted.

Page 291 of 378 4

PSTG STEP EPG STEP Cl-6 RX WATER LEVEL INCREASING, RX Cl-6 RPV WATER LEVEL INCREASING, RPV PRESSURE LESS THAN 100 PSIG PRESSURE LOW Cl-6.1 If Rx pressure is increa- If RPV pressure is increasins, sing, EMERGENCY RX DE- EMERGENCY RPV DEPRESSURIZATION IS PRESSURIZATION IS RE- REQUIRED. When RPV pressure is ,

QUIRED. decreasing, ente.r (procedure dev- I eloped from the RPV Control Guide-

1. When Rx pressure is line) at (step RC/L).

decreasins, enter the procedure developed Otherwise, enter (procedure dev-from the Rx Control eloped from the RPV Control Guide-Guideline at step line) at (step RC/L].

RC/L.

C1-6.2 Otherwise, enter the pro-cedure developed from the .

Rx Control Guideline at step RC/L.

, JU$TIFICATION OF DIFFERENCE l

The reactor pressure which defines the boundary between intermediate and low reactor pressure in step Cl-3 is inserted to clarify the step.

Page 292 of 378 e

PSTG STEP EEG STEP Cl-7 RX WATER LEVEL DECREASING, RX Ci-7 RPV WATER LEVEL DECREASING, RPV PRESSURE GREATER THAN 100 PSIG PRESSURE HIGH OR INTERMEDIATE Cl-7.1 If HPCI, RCIC, l#3. #41 If HPCI or RCIC is not operating, or CRD is not restart whichever is not operating.

operating, restart which-ever is not operatins. If no injection subsystem is lined up for injection with at least one Cl-7.2 If no injection subsystem pump running, start pumps in al-is lined up for injection ternate injection subsystems which with at least one pump are lined up for injection.

running, start pumps in alternate injection sub- When RPV water level drops to ,

systems which are lined (-164 in. (top of active fuel)):

up for injection.

• If no system, injection sub-Cl-7.3 When Rx water level drops system or alternate injection to 0 in. on Post Accident subsystem is lined up with at Flooding Range Instrumant least one pump running, STEAM (top of active fuel): COOLING IS REQUIRED. When any system, injection subsystem or  :

1. If no system, injec- alternate injection subsystem is tion subsystem, or al- lined up with at least one pump -

ternate injection sub- running, return to (step Cl-3) .

system is lined up with at least one pump ' Otherwise, EMERGENCY RPV DEPRES-  ;

running, STEAM COOLING SURIZATION IS REQUIRED. When IS REQUIRED. RPV water level is increasing or RPV pressure drops below (100

- When any system, psig (HPCI or RCIC low pressure injection subsystem, isolation setpoint, whichever is or alternate injec- higher)], return to (step Cl-3).

tion subsystem is lined up with at leact one pump run-ning, return to step Cl-3.

2. Otherwise, EMERGENCY RX DEPRESSURIZATION IS REQUIRED.

Page 293 of 378

- When Rx watcr 1? vel is increasing or Rx pressure drops below 100 psis (HPCI low pressure isolation setpoint), return to step Cl-3.

JUSTIFICATION OF DIFFERENCE The PSTG step includes PSTG cautions 3 and 4 which address HPCI and/or RCIC operation. These cautions are included since some direction is provided for operation of these systems.

The CRD system is specified in the PSTG since it will also inject water at high pressure.

O inches on the Post Accident Flooding Range is top of active fuel.

100 psig is the HPCI low pressure isolation setpoint.

Page 294 of 378 9

PSTG STEP EPG STEP Cl-8 RX WATER LEVEL DECREASING, RX RPV WATER LEVEL DECREASING, UPV PRES-PRESSURE LESS THAN 100 PSIG SURE LOW 01-8.1 Line up'for injection, [If no HPCS or LPCS subsystem is oper-start pumps, and irre- ating,] start pumps in alternate in-spective of pump NPSH jection subsystems which are lined up limits, inceeaae injec- for injection.

tion flow to the-maximum with all systems and If RPV pressure is increasing, EMERGEN-injection subsystems. CY RPV DEPRESSURIZATION IS REQUIRED.

Cl-8.2 When Rx water level drops When RPV vater level drops to [-164 fn.

. to 0 in, on Post Accident (top of active fuel)], enter (proce-Flooding Range Instru- dure developed from CONTINGENCY #4].

ments (top of active fuel), EMERGENCY RX DEPRESSURIZATION IS RE-QUIRED.

1. Line up for injection, start pumps, and increase itjection flow to .he maximum with all alter-nate injection subsys-tems.

Cl-8.3 If Rx water level can-not be restored 'nda main-tained above 0 in. on Post Accident Flooding Range Instruments (top of active fuel), enter the procedure developed from COIC.TNGENCY 7.

JUSTIFICATION OF DIFFERENCE Core covering is the preferred means of assuring adequate core cooling. Therefore with level decreasing and pressure low it is prudent to inject with systems and injection subsystems irrespective of NPSH limits since operation of systems in this condition is not expected to cause immediate system damage and in light of possible core uncovery, it is an acceptable risk.

Page 295 of 378 4 - .-.y. _ _ , _ . , ,

If th3 praferred cystsms and injsetion subsystems are untble to maintcin level above top of active fuel, emergency depressurization is required to reduce pressure and get maximum flow from systems and injection subsystems and allow use of the alternate injection subsystems. many of which do not provide substantial flow until Rx pressure drops below 100 psig. Therefore the action is conditioned on level rather than Rx pressure.

If level cannot be maintained or restored above TAF, the operator is directed to PSTG contingency 7, which norresponds to EPG Contingency 4.

The actions of the EPG step are accomplished in the PSTG step Cl-8 with additional direcrians for system use to restore level and assure adequate core cooling by core c -ring rather than proceeding to PSTG C7/EPG C4, "Core Cooling Without Level .estoration", which is a less desirable means of assuring adequate core cooling. When level restoration is not possible the operator is directed to C7/C4. Therefore it is appropriate to make every effort to restore level before going to Core Cooling Without Level Restoration.

Page 296 of 378

.. . - _ , . . .. . . ___., .. .-- . .__.--. _ _ _ . . _ . - . _ . . .. _. ~

l l

\

V l'

PSTG STEP EPG STEP No corresponding' step. The EPG includes an alternate format i for steps Cl-3 through Cl-8.

9 l'

t 1

i f

i d

I i '

h I

JUSTIFICATION OF DIFFERENCE The PSTGs do not list the alternate format since it is primarily a document of technical concerns.

Page 297 of 378 9

. s c-e = e --te, y m y ww-my-- ne - me -- *-= r re gP

PSTG STEP EPG STEP C2-1 When either: C2-1 When either:

- Any control rod is 1f11

• Boron Injection is l#13. #141 not inserted to or required and all beyond position 02 (Maximum injection into the RPV except Suberitical Banked Withdrawal from boron injection systems Position) and all injection and CRD has been terminated and into the Rx except from boron prevented, or injection systems and CRD has been stopped and prevented, or

• Boron injection is not required,

- All control rods are inserted to or beyond position 02 (Maximum suberitical Banked Withdrawal Position) 11!1TIFICATIOri 0F DIFFEREliCE Caution #13 and 14 are omitted from this step. See the justification in the

' cautions' section of this document.

The PSTG water level caution is added because Emergency Rx depressurization will cause rapid depressurization below 500 psig, and therefore the caution provides needed information.

In the EPG, the phrase ' Boron Injection is required' is contingent on two conditions:

1) Control rods not inserted to or beyond the Maximum Suberitical Banked Withdrawal Position, and

2) the Rx is not shutdown before the suppression pool temperature reaches the Boron Injection Initiation Temperature.

In the PSTGs, this guidance is more explicit. The subsequent actions are based l on ecntrol rod position alone. This simplifies the procedure. This action also agrees with changes te the EPGs after Revision 3.

I i

l Page 298 of 378 O

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

l

- PSTG STEP EPG STEP-No corresponding step. C2-1.1 Initiate IC.

JUSTIFICATION OF DIFFERENCE BFN does not have isolation condenser. Therefore the instruction is not applicable.

Page 299 of 378 2

i, -s PSTG STEP EPG STEP C2-1.1 If a high dyrwell pressure No corresponding step.

ECCS initiation signal (2.45 psig (drywell pressure which initiates ECCS)] exists, pre-vent injection from these CS and LPCI' pumps not required to assure adequate core cooling.

JUSTIFICATION OF DIFFERENCE EPG caution 11 is incorporated here as a PSTG step because it is appropriate to prevent injection from these systems if adequate core cooling is ensured to minimize Rx water level control problems which would be caused by unnecessary injection of Core Spray and LPCI pumps when the reactor is depressurized below their shutoff heads.

Page 300 of 372 9e e e e

• e em a

- 4%, w. .-p w . m,.-- - -.

.l s -

PSTG STEP EPG STEP C2-1.2 If suppression pool water C2-1.2 If suppression pool water level level is above 5.5 ft. is above (4 ft. 9 in. (elevation (elevation of top of SRV dis- of top of SRV discharge de-charge device): vice)):

1. Open all ADS valves. Open all ADS valves.

2. If any ADS valve cannot

• If any ADS valve cannot be be opened, open other opened, open other SRVs until SRVs until a total of six [7 (number of SRVs dedicated (number of SRVs dedicated to ADS)] valves are open.

to ADS) valves are open.

JUSTIFICATION OF DIFFERENCE BFN specific numbers are inserted in the PSTG.

Page 301 of 378

- , , - - , - - . ,-n n --

PSTG STEP EPG STEE C2-1.3 If less than three (Minimum C2-1.3 If less than (3 l#22l Number of SRVs Required for (Minimum Number of Emergency Rx Depressurization) SRVs Required for Emergency SRVs are open and Rx pressure Depressurization)) SRVs are open is at least 50 psig (Minimum (and RPV pressure is at least SRV Re-opening Pressure) above 50 psig (Minimum SRV Re-opening suppression chamber pressure, Pressure) above suppression rapidly depressurize the Rx, chamber pressure], rapidly defeating isolation interlocks depressurize the RPV using one if necessary, using one or or more of the following systems more of the following systems: (use in order which wil' mini-mize radioactive release to the

- Main condenser, bypassing environment):

MSIV and main steam line drain low-low-low water

• Main condenser level isolation interlocks

• RHR (steam condensing mode)

• [0ther steam driven equipment]

- Other steam driven equip-

• Main steam line drains ment such as steam seals,

• HPCI steam line SJAEs, off gas preheater

• RCIC steam line

• Head vent

- Main steam line drain by- IC tube side vent passing MSIV and main steam line drain low-low-low water level isolation interlocks

- HPCI, bypassing test mode interlocks

- RCIC, bypassing test mode interlocks, RCIC 1c4 pres-sure isolation interlocks, and high level trip logic

- Rx head vent JJ!STIFICATION OF DIFFERENCE The Brf. specific action levels are inserted in the PSTG. The BFN systems which wl:1 acecmplish depressurization are listed while RHR (steam condensing) and IC tube side vent are omitted because BFN doesn't have these systems or modes er operation. Other steam driven equipment that is capable of affecting Rx depressurization is listed.

Page 302 of 378 W

D3fect of isolation interlocks if neceassry is apccifisd bactute it is important to rapidly depressurize the reactor at this point since this action will be driven by threats to containment integrity, adequate core cooling, or undetermined Rx level. At this point, MSRVs have also failed such that less than three can be opened. Note this condition is outside the design bases since multiple failures are required. The isolation interlocks specified are MSIV/MSL drains low-low-low water level isolation, HPCI and RCIC high water level trips, HPCI and RCIC test mode interlocks, and RCIC low pressure isolation. Bypassing these isolations should allow these systems to be used to provide reactor depressurization. Note high flow, high temperature, high radiation isolations are not bypassed and will still provide protection against line breaks and release of radioactivity.

No prioritization of systems is provided because this will depend on the event.

The EPG statement '(use in ordar which will minimize radioactive release to the environment)' is omitted since little guidance can be provided to make that determination beforehand and since the high radiation level isolations remain intact, this omission is appropriate.

Page 303 of 378

PSTG STEP EPG STEP If Rx water level cannot be deter- If RPV Flooding is required, enter mined, enter the procedure developed [ procedure developed from CONTINGENCY from CONTINGENCY 4. #6] .

\

JUSTIFICATION OF DIFFERENCE Rx water level cannot be determined is the only condition in the PSTGs which requires Rx flooding. In EPGs Revision 3, flooding is also required in PC/P in the belief flooding out a break will reduce pressure and temperature in containment. Subsequent investigation of this belief by the BWROG Emergency Procedure Committee showed that little additional depressurization will be gained by flooding out the break after initial depressurization associated with subcooled water flowing out the break. Hence the condition is omitted from the PSTG.

PSTG Contingency 4 is Rx flooding and corresponds to EPG Revision 3 Contingency 6.

Page 304 of 378 v, -~ ,- , -

\

PSTG STEP EPG STEP No corresponding step. CONTINGENCY #3 STEAM COOLING C3-1 Confirm initiation of IC.

JUSTIFICATION OF DIFFERENCE BFN has no isolation condenser. Therefore, the step is not appropriate.

Page 305 of 378

PSTG STEP EPG STEP CONTINGENCY #3 No corresponding step.

STEAM COOLING C3-1 Make continued attempts to get injection systems, injection subsystems, or alternate in-jection subsystems lined up-for injection with at least one pump running.

JUSTIFICATION OF DIFFERENCE During execution of this procedure, continued efforts to establish a means of injection is important. Long term adequate core cooling depends on maintaining a source of-injection. Therefore while this procedure is executed, in effect buying time, it is appropriate to continue to attempt to establish a source of injection. This, in conjunction with step Cl-7.3.1, will direct the operators to return to Cl-3 if (when) any system capable of injecting water into the vessel is restored.

Page 306 of 378 e

PSTG STEP EPG STEE If while executing steps C3-1.1 and If while executing the following steps C3-1.2: Emergency RPV Depressurization is required or any system, injection

- Emergency Rx Depressurization is subsystem, or alternate injection sub-required, or system is lined up for injection with

- Rx water level cannot be deter- at least one pump running, enter (pro-mined, or cedure developed from CONTINGENCY #2].

- Any injection system, injection subsystem, or alternate injection subsystem is lined up for injec-tion with at least one pump run-ning.

enter the procedure developed from CONTINGENCY #2.

JUSTIFICATION OF DIFFERENCE The condition Rx water level cannot be determined is added since Rx water level must be determined to accomplish this procedure. If it is not known it is appropriate to exit this procedure and proceed to Contingency 2.

Page 307 of 378 O

PSTG STEP EPG STEP ,

C3-1.1 When Rx water level drops to If-IC cannot be initiated:

-100 in. on Post Accident Flooding Range Instruments When RPV vater level drops to (-272 in.

(Minimum Zero-Injection Rx (Minimum Zero-Injection RPV Water water level), open one SRV. Level)) or if RPV water level cannot be determined, open one SRV.

JUSTIFICATION OF DIFFERENCE BFN has no isolation condenser so the conditional statement is not appropriate and is omitted. .

-100 inches (100 inches below nominal top of active fuel) is the minimum zero injection water level per Appendix C-19.0.

The "if RPV vater level cannot be determined" is omitted from the PSTG step since if Rx water level cannot be determined and is below the minimum zero injection Rx water level, steam flow through one SRV will not provide adequate core. cooling.

The operator has previously been directed to C2 by the override preceding this step.

Page 308 of 378

PSTG STEP EPG STEP C3-1.2 When Rx pressure drops below When RPV pressure drops below [700 700 psig (Minimum Single SRV psig (Minimum Single SRV Steam Cooling Steam Cooling Pressure), enter Pressure)), enter (procedure developed the procedure developed from from CONTINGENCY #2].

CONTINGENCY 2.

JUSTIFICATION OF DIFFERENCE The minimum single SRV steam cooling pressure is 700 psig per Appendix C-25.0.

The PSTG makes this a step rather than an override. This is due to the fact the actions are to be taken in series. The core is adequately cooled by boiling off until the minimum zero injection Rx water level is reached, regardless of the pressure. Therefore it is appropriate to wait until that point is reached before taking this action in step C3.1.2. With no following steps an override is not appropriate.

I Page 309 of 378 I

PSTG STEP EPG STEP CONTINGENCY #4 CONTINGENCY #6 RX FLOODING RPV FLOODING JUSTIFICATION OF DIFFERENCE Due to the substantial difference between the RPV Flooding contingency in the EPGs and the Rx Flooding contingency in the PSTGs, it was thought to be appropriate to include a discussion at the beginning of this section which describes, in general, the differences betwe2n thesa two contingencies and the reasons for these differences. As with all other sections of this document, a step by step comparison of the two contingencies will follow.

In the EPGs, flooding during an ATWS (except for cases where pcwer level was undertermined or could not be maintained above the Flow Stagnation Power Level) was covered by the Level / Power Control contingency. A theoretical concept called the Flow Stagnation Power Level concept was used as an indirect means of assuring adequate core cooling. In the PSTGs, the Flow Stagnation Power Level concept has been dropped. The reasons for this are discussed in the section dealing with Contingency'#5, ' Level / Power Control'. Due to the exclusion of this material, PSTG Contingency #4, 'Rx Flooding', is required to handle all situations where Rx flooding is required including ATWS events.

Rx flooding is performed in the PSTGs only when Rx water level cannot be determined. The EPGs, however, also require Rx flooding in the event suppression chamber pressure cannot be maintained below the Primary Containment Design Pressure. The belief here was that flooding subcooled water out a break would further reduce pressure and temperature in the primary containment. Subsequent analysis by the BWR Owners Group Emergency Procedures Committee revealed that little additional benefit would be derived from this action. Therefore, it is omitted from the PSTG.

These changes made the resequencing of steps from EPG Contingency 6 into PSTG Contingency 4 necessary. The PSTG directs actions to flood the Rx for.both ATWS and non-ATWS events, and except for the primary containment requirement which is omitted, the PSTG Rx Flooding contingency satisfies the intent of the EPG RPV Flooding contingency.

Page 310 of 378

PSTG STEP EPG STEP If while executing steps C4-1 through 'If while executing the following step,  ;

C4-5 Rx water level can be deter- RPV water level can be determined and mined: RPV Flooding is not required, enter (procedure developed from CONTINGENCY

1. 7] and (procedure developed from the

~

- If any control rod is not inserted to or beyond position 02 (Maximum RPV Control Guideline', at (Step RC/P-4]

Suberitical Banked Withdrawal Pos- and execute these r'.ocedures concur-ition), disable ADS auto blowdown rently, function and encer the procedure developed from CONTINGENCY 5 and the procedure developed from the Rx Control Guideline at step RC/P-4 and execute these procedures concurrently.

- If all control rods are inserted to or beyond position 02 (Max-imum Suberitical Banked Withdraw-al Position), enter the procedure developed from the Rx Control Guideline at steps RC/L and RC/P-4 and execute these sections concurrently.

JUSTIFICATION OF DIFFERENCE In this PSTG, this override is placed at the beginning of the contingency because it applies to flooding under both ATWS and non-ATWS conditions. The EPG contingency 6 contains this override in the section which deals with flooding under ATWS conditions, other than loss of level indication. As previsouly discussed, the PSTG does away with this requirement to flood. Therefore, since this override applies to both ATWS and non-ATWS situation where water level indication is not lost, it is appropriate to place this override at the beginning of the contingency.

Page 311 of 378 e

w -

1 PSTG STEP EPG STEP No corresponding step. If while executing the following steps, RPV water level can be determined, continue in this procedure at (Step C6-6].

J.USTIFICATION OF DIFFERENCE This EPG step corresponds to the PSTG override which precedes step C4-1.

In the PSTG, this override is placed at the beginning of the contingency because it applies to flooding under both ATWS and non-ATWS conditions. The EPG contingticy 6 contains this override in the section which deals with flooding under ATWS conditions only. It does not contain this override in the section dealing with flooding under non-ATWS conditions because the EPG requires flooding for a condi* ion other than loss of level indication. As previously discussed, the PSTG does away with this requirements to flood. Therefore, since this override applies

! to both ATWS and non-ATWS situations where water level indication is not lost, it is appropriate to place this override at the beginning of the contingency, i

l I

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Page 312 of 378 a

p - , , _ . - - ,. - -

PSTG STEP EPG STEP C4-1 If any control rod is not C6-2 If any control rod is not insert-inserted to or beyond position ed beyond postion [06 (Maximum 02 (Maximum Suberitical Suberitical Banked Withdrawal Banked Withdrawal Position), Position)]:

flood the Rx as follows:

4 i

4 S

LUSTIFICATION OF DIFFERENCE The additional wording "flood the Rx as follows:" clarifies the PSTG. The following steps in both EPG and PSTG provide for flooding the Rx under ATWS conditions. 02 is the maximum suberitical banked withdrawal position for BFN.

Page 313 of 378 e

PSTG STEP C4-1.1 Stop and prevent all injection into the Rx except from boron injection systems and CRD until Rx pressure is below the Minimum Alternate Rx Flooding Pressure.

MINIMUM ALTERNATE RX NUMBER OF OPEN SRVs FLOODING PRESSURE (psig) 6 or more 190 5 210 4 260 3 320 2 440 1 830 t EPG STEP C6-2.1 Terminate and prevent all injection into the RPV except fro: boron injection systems and CRD until RPV pressure is below the Minimum Alternate RPV Flooding Pressure.

- MINIMUM ALTERNATE RPV NUMBER OF OPEN SRVs FLOODING PRESSURE (psig) 7 or more 155 6 185 5 225 4 285 3 385

._1 53 1 _.

JUSTIFICATION OF DIFFERENCE The Minimum Alternate Rx Flooding Pressures per Appendix C-21.0 are inserted in the PSTG.

Page 314 of 378 4

PSTG STEP' EPG STEP

1. If less=than one (minimum number If less than [2 (minimum number of SRVs of SRVs for which the Minimum for which the Minimum Alternate RPV Alternate Rx Flooding Pressure Flooding Pressure is below the lowest is below the lowest SRV lifting SRV lifting pressure)] SRVs can be pressure) SRV can be opened, opened, continue in this procedure, continue in this procedure.

JUSTIFICATION OF DIFFERENCE One is the minimum number of SRVs for which the Minimum Alternate Flooding Pressure is below the lowest SRV listing pressure per Appendix C-21.0.

Page 315 of 378 a

PSTG STEE EPG STEP C4-1,2 If at least three (Minimum C6-1 If at least (3 (Minimum Number Number of SRVs Required for of SRVs Required for Emergency Emergency Depressurization) Depressurization)) SRVs can be SRVs can be opened: opened or if HPCS or motor driven feedwater pumps are available for

1. Close the MSIVs. injection, close the MSIVs, main

2. Close the main steam line steam line drain valves, IC, HPCI, drains. RCIC and RHR steam condensing

3. Close the RCIC steam line isolation valves.

Isolation valves.

JUSTIFICATION OF DIFFERENCE There are two PSTG steps which correspond to the EPG step and neither occur in the same sequence as the EPG step. This is because the action to isolate steam lines was thought to be less critical than terminating injection into the vessel for ATWS events. In the section of this contingency dealing with ATWS the step was relocated further down in the procedure. This caused the need to have this step duplicated; appearing in both the ATWS section and the non-ATWS section of this contingency.

Three is the minimum number of SRVs required for emergency depressurization at Browns Ferry. per Appendix C-17.0.

The phrase "or if HPCS or motor driven feedwater pumps are available for injection" is omitted since Browns Ferry does not possess a HPCS or motor driven f edwater pumps.

IC and RHR steam condensing isolation valves are omitted from the actions because BFN does not possess an IC or the RHR steam condensing mode.

Direction to isolate the HPCI steam line is purposely omitted from this step. The Rx depressurization action carried out in Contingency #2 will cause HPCI to automatically isolate on low RPV pressure if HPCI is in operation when Contingency

1. 4 is entered. Even if the automatic HPCI isolation fails to function, the HPCI system steam demand reduces Rx pressure to the turbine stall speed for reactor power levels at or belov the decay heat range. Until this occurs, HPCI injection flow to the Rx is maintained for as long as possible thus assiscing in floodup of the Rx. O.? H- 1 other hand, RCIC is isolated in order to preserve its ability to provide it.Je. tion should it later be needed under conditions when all motor-driven pumps are incapable of adequately flooding the Rx.

Page 316 of 378 e

.__m

PSTG STEP EPG STEP C4-1.3 Commence and, 1111 C6-2.2 Commence and slowly l#25l irrespective of pump increase injection into NPSH limits, slowly increase the RPV with the following injection into the Rx with the systems until at least [2 (min-following systems until at least imum number of SRVs for which one (minimum number of SRVs for the Minimum Alternate RPV Flood-which the Minimum Alternate ing Pressure is below the lowest Rx Flooding Pressure is below SRV lifting pressure)] SRVs are the lowest SRV lifting pressure) open and RPV pressure is above SRV is open and Rx pressure is the Minimum Alternate RPV F1.ood-above the Minimum Alternate Rx ing Pressure:

Flooding Pressure:

• Motor driven feedwater pumps

- Condensate

• Condensate pumps

- CRD

• CRD

- LPCI, bypassing RHR injection (* LPCI]

valve timers if necessary; place applicable RHRSW pump (s) in operation as soon as possible.

JUSTIFICATION OF DIFFERENCE The PSTG implements this action ' irrespective of pump NPSH limits'. This is appropriate becausa at this point Rx water level cannot be determined and adequate core cooling is not assured until flooding conditions are established. Therefore, the threat to adequate core cooling takes priority over the possible damage to LPCI operating beyond its NPSH limit.

One is the minimum number of SRVs for which the Minimum Alternate Rx Flooding Pressure is below the lowest SRV lifting pressure.

Browns Ferry does not possess motor driven feedwater pumps and they are omitted from the system list.

LPCI injects outside the shroud and is therefore included in the list.

EPG caution #4 is incorporated in the step here. However, since Browns Ferry does not have the capability to bypass the RUR heat exchangers, the statement used to meet the intent of caution #4 is "place applicable RHRSW pump (s) in operation as soon as possible". Execution of this action maximizes cooling of the water being injected and provides early decay heat removale Page 317 of 378

/

The RHR injection valve timers do not permit throttling of the injection valve for five minutes following an accident signal. To slowly increase level using LPCI will require the timers to be bypassed.

PSTG caution #5 corresponds to EPG caution #25.

l Page 318 of 378

, PSTG STEP EPG STEP C4-1.4 If at least one (minimum number If at least [2 (minimum number of SRVs of SRVs for which the Minimum for which the Minimum Alternate RPV Alternate Rx Flooding Pressure Flooding Pressure is below the lowest is below the lowest SRV lifting SRV lifting pressure)) SRVs are not open pressure ) SRV is not open or or RPV pressure cannot be increased to Rx pressure cannot be increased above the Minimum Alternate RPV Flood-to above the Minimum Alternate ing Pressure, commence.and slowly in-Rx Flooding Pressure, commence crease injection into the RPV with the and, irrespective of pump NPSH following systems until at least (2 limits, slowly increase injec- (minimum number of SRVs for which the tion into the Rx with the Minimum Alternate 2PV Flooding Pressure following systems until at is below the lowest SRV lifting pres-least one (minimum number of sure)) SRVs are open and RPV pressure SRVs for which the Minimum is above the Minimum Alternate RPV Alternate Rx Flooding Pressure Flooding Pressure:

is below the lowest SRV lifting pressure) SRV is open and Rx HPCS pressure is above the Minimbm

• LPCS Alternate Rx Flooding Pressure:

• RHR service water crosstie Fire System CS

• Interconnections with other units

- Condensate transfer to RHR ECCS keep-full systems and CS RHR crosstie to other units

- Standby coolant

- RHR drain pumps

- PSC head tank pumps 1MSTIFICATION OF DIFFERENCE

^

One is the minimum number of SRVs for which the Minimum Alternate Rx Flooding Pressure is below the lowest SRV lifting pressure per Appendix C-21.0.

This action is accomplished irrespective of pump NPSH limits because conditions have not been established for Rx flooding and adequate core cooling may not be assured. The possibility of system damage has less priority than assuring adequate core cooling.

HPCS is omitted from the list of systems since BFN does not have High Pressure Core Spray.

The BFN alternate injection subsystems are inserted in the PSTG.

Page 319 of 378

PSTG STEP EPG STEP C4-1.5 If at least one (minimum No corresponding step.

number of SRVs for which the Minimum Alternate Rx Flooding Pressure is below the lowest SRV lifting pres-sure) SRV is not open or Rx pressure cannot be increased to above the Minimum Alter-nate Rx Flooding Pressure, restart RCIC, defeating low Rx pressure isolation inter-locks and high Rx water level turbine trip if necessary, and increase injection flow to the maximum.

JUSTIFICATION OF DIFFERENCE If the conditions for Rx flooding cannot be established with either the preferred floeding systems or the less desirable, outside the shroud injection sources, RCIC is the last system the operator has available to inject to the Rx. To operate the RCIC system in this situation it may be necessary to defeat the low Rx pressure isolation and allow the system to run at Rx pressures approaching turbine stall.

RCIC operation may also require defeating the high Rx water level trip logic.

RCIC operation may be improperly inhibited by logic that cannot accurately determine Rx water level any better than the operator. Defeating the high Rx water level trip may risk flooding the RCIC system steam lines. However, the RCIC turbine is a stout, durable machine which is believed to be able to remain intact should such a condition arise. Certainly the inability to provide sufficient Rx injection flow at this point leaves the sperator with no better option but to take the risk of equipment damage. This action is required only when water' level cannot be determined and multiple failures have prevented the use of low pressure motor-driven systems. Regardless, under these conditions, it is the appropriate action to take.

Page 320 of 378

PSTG STEP EPG STEP C4-1.6 When at least one (minimum C6-2.3 Maintain at least (2 (minimum number of SRVs for which number of SRVs for which the the Minimum Alternate Rx Minimum Alternate RPV Flooding Flooding Pressure is below Pressure is below the lowest the lovest SRV lifting pres- SRV lifting pressure)] SRVs sure) SRV is open and Rx open and RPV pressure above pressure is above the Minimum the Minimum Alternate RPV Alternate Rx Flooding Pres- Flooding Pressure by throttling sure, control injection to injection.

maintain at least one (minimum number of SRVs for which the Minimum Alternate Rx Flooding Pressure is below the lowest SRV lifting pres-sure) SRV open and Rx pres-sure above the Minimum Alter-nate Rx Flooding Pressure but as low as practicable.

JUSTIFICATION OF DIFFERENCE The appropriate BFN specific numbers per Appendix C-21.0 are inserted. The EPG step is reworded to clarify the intent, i.e. first establish flooding conditions and then throttle injection to maintain flooding conditions but do so such thct floodits occurs at as slow a rate as possible. This assures adaquate core cooling and eventual vessel refill but minimizes the possibility of a power excursion.

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l Page 321 of 378 l

r-PSTG STEP EPG STEP C4-1.7 When all control rods are C6-2.4 When:

inserted to or beyond pos-ition 02 (Maximum Suberit-

• All control rods are inserted' ical Banked Withdrawal Pos- beyond position (06-(maximum ition), continue in this suberitical banked withdrawal procedure, position)], or The reactor is s 'n!Lsn and no boron has been injected into the RPV, continue in this procedure.

b JUSTIFICATION OF DIFFERENCE 02 is the maximum suberitical banked withdrawal position for 3FN. The secord EPG condition is omitted because there is no reasonable way to expect the, operator to determine the reactor is shutdown (and will remain shutdown) if all rods aren't fully inserted and no boron has been injected. Therefore, it is omitted. Waiting on all rods inserted before proceeding is appropriate.

Page 322 of 378

., - _ m PSTG STEP EPG STEP C4-2 If at least,three (Minimum C6-1 If at least [3 (Minimum Number Number of SRVs Required for of SRVs Required for Emergency Emergency Depressurization) Depressurization)) SRVs can be SRVs can be opened: apened or if HPCS or motor driven feedwater pumps are available for

1. Close the MSIVs. injection, close the MSIVs, main

2. Close the main steam line steam line drain yap 's, IC, HPCI, drains. RCIC and RER steam condensing

3. Close the RCIC steam line isolation valves.

isolation valves.

JUSTIFICATION OF DIFFERENCE There are two PSTG steps which correspond to the EPG step and neither occur in the same sequence as the EPG step. This is because the action to isolate steam lines was thought to be less critical than terminating injection into the vessel for ATWS events. In the section of this contingency dealing with ATWS the step was relocated further down in the procedure. This caused the need to have this step duplicated; appearing in both the ATWS section and the non-ATWS section of this contingency.

Three is the minimum number of SRVs required for emergency depressurization at

• Browns Ferry per Appendix C-17.0.

The phrase 'or if HPCS or motor driven feedwater pumps are available for injection' is omitted since Browns Ferry does not possess a HPCS or motor driven feedwater pumps.

IC and RHR steam condensing isolation valves are omitted from the actions because BFN does not possess an IC or the RHR steam condensing mode.

Direction to isolate the HPCI steam line is purposely omitted from this atep. The Rx depressurization action carried out in Contingency #2 will cause HPCI to automatically isclate on low RPV pressure if PPCI is in operation when Contingency

1. 4 is entered. Even if the automatic HPCI isolation fails to function, the HPCI System steam demand reduces Rx pressure to the turbine stall speed for reactor power levels at er below the decay heat range. Until this occurs, HPCI injection flow to the Rx is maintained for as long as possible this assisting in ficodup of the Rx. On the other hand, RCIC is isolatcd in order to preserve its ability to provide injection should it later be needed under conditions when all motor-driven pumps are incapable of adequately flooding the Rx.

Page 323 of 378 9

PSTG STEP EPG STEP C4-3 Flood the Rx as follows: C6-3 If RPV water level cannot be determined:

, JUSTIi'ICATION OF DIFFEREMGE PSTG step C4-3 and EPG atep C6-3 address flooding when all control rods are inserted. Following both steps are the appropriate steps to flood. As previously discussed, the PSTG procedure is executed only when Rx water level can't be determined. Therefore it is not necessary to repeat the phrase at this point.

I 1

Page 324 of 378

_ . . _ ~

PSTG STEP EPG STEP C4-3.1 Commence, and irrespective of C6-3.1 Commence and increase injection pumps HPSH limits, increase into the RPV with the following injection into the Rx with systems until at least (3 the following systems until (Minimum Number of SRVs Re-at least three (Minimum quired for Emergency Depressur-Number of SRVs Required for ization)) SRVs are open and Emergency Depressurization) RPV pressure is not decreasing SRVs are open and Rx pressure and is at least [77 psig is not decreasing and is 70 (Minimum RPV Flooding Pres-psig (Minimum Rx Flooding sure)] above suppression cham-Pressure) or more above ber pressure.

suppression chamber pressure.

• HPCS

- Condensate

• Motor driven feedwater pumps

- LPCI

• LPCS

- CS

• LPCI

- CRD

• Condensate pumps

- Condensate transfer to RHR

• CRD and CS

• RHR service water crosstie

- SLC (test tank)

• Fire System

- SLC (boron tank)

• Interconnections with other

- RHR crosstie to other units units

- Standby coolant

• ECCS keep-full systems

- RHR drain pumps

• SLC (test tank)

- PSC head tank pumps

• SLC (boron tank)

- RCIC (using aux. boiler steam)

- HPCI (using aux. boiler steam)

JUSTIFICATION OF DIFFERENCE Flooding is required when Rx water level cannot be determined and thus adequate core cooling is .mt assured until flooding cenditions are established. Therefore, it is appropriate to establish flooding irrespective of pump NFSH limits.

The BFN specific number (Minimum Number of SRVs Required for Emergency Rx Depressurization and the Minimum Rx Flooding Pressure) are inserted per Appendices C-17.0 and C-22.0.

HPCS and motor driven feedwater pumps are omitted from the systems list because BFN does not have them.

The BFN specific Alternate Injection Subsystems are inserted.

Page 325 of 378 6

PSTG STEP EPG STEP

1. If at least three (Minimum No corresponding step.

Number of SRVs Required for Emergency Depressurizat.',on)

SRVs are not open or Rx pres-sure cannot be maintained at least 70 psig (Minimum Rx Flooding Pressure) above sup-pression chamber pressure, restart RCIC, defeating low Rx pressure isolation inter-locks and high Rx water level turbine trip if necessary, and increase injection flow to the maximum.

JUSTIFICATION OF DIFFERENCE If the con'itions for Rx ficcding cannot be established with either the preferred flooding systers or the less desirable, outside the shroud injection sources, RCIC is the last syntem the operator has available to inject to the 1x. To operate the RCIC system in this situation it may be necessary to defeat the low Rx pressure isolation and allow the system to run at Rx pressures approaching turbine stall.

RCIC operation may also require defeating the high Rx water level trip logic.

RCIC oper.aion may be improperly inhibited by logic that cannot accurately determine Rx water level any better than the operator. Defeating the high Rx water level trip may risk flooding the RCIC system steam lines. However, the RCIC turbine is a stout, durable machine which is believed to be able to remain intact should such a condition arise. Certainly the inability to provide sufficent P.x injection flow at this point leaves the operator with no better option but to take the risk of equipment damage. This action is required only when water level can't be determined and multiple failures have prevented the L'e of low pressure motor driven systems. Regardless, under these conditions, it is the appropriate action to take.

Page 326 of 378

,- PSTG STEP EPG STEP C4-3.2 When at least three (Minimum Maintain at least (3 (Minimum Number Number of SRVs Required for of SRVs Required for E'mergency De-Emergency Depressurization) pressurization)) SRVs open and RPV SRVs are open and Rx pressure pressure at least (77 psig (Minimum can be maintained at least 70 RPV Flooding Pressure)) above suppres-psig (Minimum Rx Flooding sion chamber pressure by throttling Pressure) above suppression injection.

chamber pressure, control in-jection to maintain at least three (Minimum Number of SRVs Required for Emergency De-pressurization) SRVs open and Rx pressure at least 70 psig (Minimum Rx Flooding Pressure) above suppression chamber pressure but as low as prac-ticable.

JUSTIFICATION OF DIFFERENCE The appropriate BFN specific numbers per Appendices C-17.0 and C-22.0 are inserted.

The EPG step is reworded to clarify the intent; i.e. first establish flooding conditions and then throttle injection to maintain flooding. This establishes adequate core cooling but at the same time minimizes the hydraulic loads on the Rx, SRVs, and downstream piping.

Page 327 of 378 ,

s-EXIG STEP EPG STEP No corresponding step. C6-4 If RPV water level can be deter-mined, commence and increase injection into the RPV with the following systems until RPV vater level is increasing:

• HPCS

• Motor driven feedwater pumps

• LPCS

• LPCI

• Condensate pumps

• CRD

• RHR service water crosstie

• Fire System

• Interconnections with other units

• ECCS keep-full systems

• SLC (test tank)

• SLC (boron tank)

JUSTIFICATION OF DIFFERENCE If Rx water level can be determined, flooding is not required by the PSTGs for the reason discussed in the deviation for EPG step C6-1 and in the Primary Containment Control Guideline justification. Based on this the EPG step is not applicable and thus is omitted. The first override box in C4 outlines operator actions in this eventuality.

Page 328 of 378 s

r PSTG STEP EPG STEP C4-4 When:' C6-5 If RPV water level cannot be determined:

- Rx water level instrumenta-tion is available, and C6-5.1 Fill all RPV water level

- Temperatures near the cold instrumentation reference reference leg instrument columns.

vertical runs are below 212 degrees F, and Cd-5.2 Continue injecting water into the RPV until (temp-

- Rx pressure has remained at erature near the cold ref-least 70 psig (Minimum Rx erence. leg instrument vert-Flooding-Pressure) above ical runs) is below 212*F suppression chamber pressure and RPV water level instru-for at least the Minimum mentation is available.

Core Flooding Interval C6-5.3 If it can be determined that the RPV is filled or if RPV pressure is at NUMBER OF MINIMUM CORE least (77 psig (Minimum RPV OPEN SRVs FLOODING INTERVAL Flooding Pressure)] above IN MINUTES suppression chamber pres-sure, terminate all in-6 or more 19 jection into the RPV and 5 30 reduce RPV water level.

4 58 3 117 Stop all injection into the Rx and reduce Rx water level until Rx water level indica-tion is restored.

JUSTIFICATION OF DIFFERENCE +*

The first EPG sta* ? ment is redur. dant since the PSTG does not flood unless Rx water level cannot be determined- Since flooding conditions were established in previous steps it is appropriate to wait (i.e. When:) for flooding to refill the instrument reference legs and drywell temperature near the reference leg to decrease. Since we are waiting at this point for flooding to refill the reference legs, there is no need to specify filling the reference legs in a separate step. Therefore, EPG step C6-5.1 is not included in the PSTGs .

Page 329 of 378 4

m

Thero cry be no definitive means of determining that the Rx is filled cnd cimply establishing the conditions for flooding does not ensure that the Rx is filled. In work that was done subsequent to Rev. 3 of the EPGs being approved, the Minimum Core Flooding Interval was established as a means of verifying that the Rx was in fact filled after a specified interval following establishment of flooding conditions.

The Minimum Rx Flooding Pressure is calculated in Appendix C-22.0.

The Minimum Core Flooding Interval is calculated in Appendix C-30.0.

The addition of the words 'until Rx water level is restored' are added to specify the intent of the step (verifying that the water level indication is available by lowering level until it is on scale).

Page 330 of 378 5

PSTG STEP EPG STEP No corresponding step. If while executing the following steps, RPV water level can be determined, continue in this procedure at (Step C6-6].

4 JUSTIFICATION OF DIFFERENCE This EPG step corresponds to the PSTG override which precedes step C4-1.

In the PSTG, this override is placed at the beginning of the contingency because it applies to flooding under both ATWS and non-ATWS conditions. The EPG contingency 6 contains this override in the section which deals with flooding under ATWS conditions only. It does not concain this override in the section dealing with flooding under non-ATWS condition because the EPG requires flooding for a condition other than loss of level indication. As previsouly discussed, the PSTG does away with this requirement to flood. Therefore, since this override applies to both ATWS and non-ATWS situation where water level indication is not lost, it is appropriate to place this override at the beginning of the contingency,

~

i Page 331 of 378 9

-- - - - - . .,, ..--y ---

PSTG STEP C4-4.1 If Rx water level indication is not restored within the Maximum Core Uncovery Time Limit after commencing termination of injection into the Rx,

. return to step C4-3.1.

MAXIMUM CORE UNCOVERY TIME AFTER RX SHUTDOWN TIME LIMIT 1 min 3 mins 5 min 4 mins 10 min 5 mins 15 min 6 mins 20 min 6 mins 30 min 7 mins 40 min 8 mins 50 min 8 mins I hour 9 mins 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 20 mins 10 mins 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 40 mins 10 mins 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> 16 mins 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> 40 mins 19 mins 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> 27 mins 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> 35 mins p

EEG STEP C6-5.4 If RPV water level indication is not restored within the Maximum Core Uncovery Time Limit after commencing termination of injection into the RPV, return to (Step C6-3] .

JUSTIFICATION OF DIFFERENCE PSTG step C4-3.1 corresponds to EPG step C6-3. A table is used in place of a semilogarithmic graph for ease of use. The Maximum Core Uncovery Time Limit is documented in Appendix C-23.0.

Page 332 of 378

n PSTG S?IE EPG STEP C4-5 Enter the prccedure developed C6-5 When suppression chamber pressure from the Rx Control Guideline can be maintained below the at steps RC/L and RC/P-4 and Primary Containment Design Pres-execute these steps concur- sure, enter (procedure developed rently. from the RPV Control Guideline) at (Steps RC/L and RC/P-4) and

. execute these steps concurrently.

JUSTIFICATION OF DIFFERENCE The Primary Containment Design Pressure is not used to require flooding in the PSTGs as discussed in the deviation justification at the beginning of this contingency. Therefore the condition is omitted.

Page 333 of 378

PSTG STEP EPG STEP CONTINGENCY ~#5 CONTINGENCY #7 LEVEL / POWER CONTROL LEVEL / POWER CONTROL If while executing steps C5-1 through If while executing the following steps C5-4: RPV Flooding is required or RPV vater level cannot be determined, control Rx water level cannot be deter- injection int 0 the RPV to maintain mined, enter the procedure dev- reactor power above (8% (Reactor Flow eloped from CONTINGENCY 4 Stagnation Power)] but as low as prac-ticable. However, if reactor power All control rods are inserted to cannot be determined or maintained or beyond position 02 (Maximum above (8% (Reactor Flow Stagnation Suberitical Banked Withdrawal Power)], RPV FLOODING IS REQUIRED; Position), enter the procedure enter (procedure developed from developed from the Rx Control CONTINGENCY #6].

Guideline at step RC/L.

JUSTIFICATION OF DIFFERENCE PSTG Contingency 5 corresponds to Contingency 7 of the EPGs with some notable exceptions. The EPG makes use of a concept called reactor flow stagnation power.

This was believed to be the power level at which an unserammed reactor would operate, if reactor water level was lowered to the top of the active fuel (TAF).

Therefore even if level was undetermined, adequate core cooling could be' assured to maintaining reactor power at or above the reactor stagnation power level because the water level would have to be at TAF and the core covered. However, after NRC approval of EPG revision 3, subsequent studies by EPRI, Oak Ridge, and others indicated a large degree of uncertainty in the value for this number.

Because of this the BWROG Emergency Procedure Committee abandoned the concept of reactor stagnation power and later revisions of the EPGs do not include this '

concept. The PSTG is modeled after the later versions in this regard. Therefore if reactor water level cannot be determined, Rx flooding is required to assure adequate core cooling and the operator is directed to C4 to accomplish this.

The second bullet in the PSTG provides for exit from this procedure back to RC/L if at anytime all control rods are inserted to the maximum suberitical banked withdrawal position. With the reactor shutdown, it is appropriate to return to normal level control.

Page 334 of 378

a. - -

~. -

PSTG STEP EPG STEP C5-1 If: C7-1 If:

- Rx power is above 3% (APRM '

Reactor power is above (3%

downscale trip)'or cannot be (APRM downscale trip)] or determined, and cannot be determined, and Suppression pool temperature

- Suppression pool temperature is above [110*F (Boron In-is above 110 degrees F (Boron jection Initiation Tempera-Injection Initiation Temper- ture)], or ature), and

• Either an SRV is open or opens or drywell pressure is above

- Either an SRV is open or (2.0 psig (high dryvell pres-cycling at setpoint or dry- sure scram setpoint)).

well pressure is above 2.45 psig (high drywell pressure lower RPV water level l#26l scram setpoint) by terminating and pre-venting all injection into the Then perform the following: RPV except from boron injection systems and CRD until either:

C5-1.1 If any MSIV is open, bypass MSIV and main

• Reactor power drops below steam line drain valve (3% (APRM downscale trip)), or low-low-low level

• RPV water level reaches isolation and Rx build- [-164 in. (top of active ing ventilation low fuel)], or level isolation inter-

• All SRVs remain closed and o locks drywell pressure remains below (2.0 psig (high dryvell pres-C5-1.2 Lower Rx water level, sure scram setpoint)].

irrespective of any con-sequent Rx power oscil-lations, by stopping and preventing all injection into the Rx except from boron injection systems and CRD until'either:

- Rx power drops below 3% (APRM downscale trip), or

- Rx water level reaches 0 in. on Post Accident Flooding Range Instru-ments (Flow Stagnation Water Level), or Page 335 of 378

h

- All SRVs remain closed and drywell pressure.

remains below 2.45 psig (high drywell pressure scram set-point)

JUSTIFICATION OF DIFFERENCE BFN specific numbers are inserted. 3% is the APRM downscale trip, 110*F is the Boron Injection Initiation Temperature, and 2.45 psig is the nominal high dryvell pressure scram setpoint.

The PSTG replaces the words 'or opens' with 'or cycling at setpoint' to clarify the intent of the step. The SRV may not be open at the particular instant the step is read, however, the actions are still apprpriate since a cycling SRV indicates heat is periodically being added to the torus.

EPG caution 26 is incorporated into the step to clarify that oscillations are expected but the action is still required.

O inches on the post accident flooding range instruments correpsponds to TAF and is the Rx water level at which circulation flow stagnates.

An additional action is included. If any MSIV is open and conditions indicate lowering water level is necessary, level may be deliberately lowered below the MSIV low-low-low Rx water level isolation setpoint and Rx b1dg. ventilation low Rx water level isolation setpoint under conditions when it is most desirable to maintain the use of the condenser. as a heat sink. Bypassing the low level isolations therefore is appropriate. Other MSIV isolation interlocks (e.g., main steam line high radiation) are not bypassed because they provide automatic protection for conditions where reopening MSIVs is not appropriate.

9

• Page 336 of 378

PSTG STEP EPG STEP If while executing step C5-2 through If while executing the following steps C5-4 Emergency Rx Depressurization Emergency RPV Depressurization is re-is required, continue in this proce- quired, continue in this procedure dure at step C5-2.2.1. at (Step C7-2.1].

JUSTIFICATION OF DIFFERENCE PSTG step C5-2.2.1 corresponds to EPG step C7-2.1. The applicable steps are listed.for clarity.

1 i

Page 337 of 378 e

.- -w---w, - - - , - - - - - ,,-.-,e-+-- -r-- - - - - . . -- ----

l

)

l PSTG STEP EPG STEP If while executing step C5-2 and.

If while executing the following step:

associated substeps:

Reactor power is above [3% (APRM

- Rx power is above 3% (APRM down- downscale trip)] or cannot be scale trip ) or cannot be deter- determined, and mined, and RPV water level is above (-164 in.

Rx water level is above 0 in. on (top of active fuel)), and Post Accident Flooding Range instruments (Flow Stagnation Water

• Suppression pool temperature is Level), and above (110*F (Boron Injection In-itiation Temperature)), and

- Suppression pool temperature is above 110 degrees F (Boron In-

• Either an SRV is open or opens or jection Initiation Temperature), drywell pressure is above (2.0 psig and (high drywell pressure scram setpoint)],

- Either an SRV is open or cycling -

at setpoint or drywell pressure return to (Step C7-1] .

is above 2.45 psig (high drywell pressure scram setpoint) return to step C5-1.

JUSTIFICATION OF DIFFERENCE The BFN specific values are inserted as discussed in PSTG step CS-1. 'The substitution of 'or cycling'at setpoint' for 'or opens' is also discussed in that deviation. PSTG step CS-1 corresponds to EPG step C7-1.

Page 338 of 378 4

PSTG STEP EPG STEP C5-2 Maintain Rx water 1g11 C7-2 Maintain RPV #9, #10, level either: water level either: #11. #25 If Rx water level was delib-

• If RPV vater level was deliberately erately lowered in step C5-1, lowered in (Step C7-1), at the at the level to which it was level to which it was lowered, or lowered, or

• If RPV water level was not deliber-

- If Rx water level was not ately lowered in (Step C7-1], be-deliberately lowered in step tween (+12 in. (low level scram set-C5-1, between +11 in. (low point)] and (+58 in. (high level level scram setpointi and +54 trip setpoint)],

in. (high level trip set-point) with the following systems:

with the following systems:

• Condensate /feedwater system (1110 -

O psig (RPV pressure range for sys-

- Condensate /feedwater tem operation))

- CRD

- LPCI, bypass the LPCI injec- ' CRD system (1110 - O psig (RPV pres-tion valve timers if neces- sure range for system operation))

sary, control and maintain RHR pump flow less than the

• RCIC system (1110 - 50 psig (RPV RHR pump NPSH limit (see pressure range for system operation))

Figure B); place applicable RHRSW pump (s) in service as

• HPCI system (1110 - 100 psig (RPV soon as possible -

• pressure range for system opera-

- RCIC with suction #3 tion)]

from CST, defeating _JBL.

Rx pressure isolation

• LPCI system (250 - O psig (RPV interlocks if necessary pressure range for system opera-

- HPCI, with suction Illi tion))

from the CST, defeating high suppression pool water level suction transfer logic interlocks if suppression pool temperature is above 140*F.

Page 339 of 378

- ~ - - - - - - - + , - -y - --,

JUSTIFICATION OF DIFFERENCE PSTG step C5-1 corresponds to EPG step C7-1.

The BFN nominal values for low level scram setpoint and high level turbine trip setpoint are inserted.

The operating pressures for the systems are omitted from the PSTG as being unnecessary information. The operators are familiar enough with these systems so as not to need this information.

Details of operation for LPCI are given for the following reasons: the LPCI injection valve timers prevent throttling LPCI for 5 minutes following an accident signal. Throttling LPCI will very probably be required to limit level as called for in this step. Therefore bypassing the timer is appropriate and meets the intent of the EPG step; caution 4 of the EPGs is implemented in the step specifying placement of RHRSW pump (s) in service as soon as possible; caution 8 of the EPGs is implemented in the step to maintain NPSH limits for RER, at this step adequate core cooling is not threatened and it is appropriate to protect the equipment.

Details are specified for RCIC system operation. Lineup to the CST is specified because this source of water is of higher quality than the suppression pool and is not subject to the temperature increas'e the suppression pool is (threatening NPSH requirements and bearing lube oil temperature requirements). It is also anticipated auxiliary systems or other means will be available to refill the CST if necessary. This argument is applicable for HPCI also.

Low pressure interlocks (designed for equipment protection and not to implement a technical specification requirement) may be defeated if necessary because some injection into the reactor can still be sustained at very low reactor pressures (just above the turbine stall pressure). This may be done without seriously threatening RCIC operation. This action is appropriate under these conditions.

HPCI details of operation are specified for the same reasons as RCIC pertaining to CST. Defeat of the suppression pool high level interlock if suppression pool temperature is greater than 140*F is appropriate since HPCI NPSH and bearing lube oil temperatures may be threatened.

EPG caution 12 corresponds to PSTG caution 3. EPG caution 25 corresponds to PSTG caution 5.

EPG cautions 9, 10, and 11 are omitted from this step. See the ' cautions' section of this document for the justification.

Page 340 of 378 e

'g.

PSTG STEP EPG STEP b '

C5-2.1 If Rx vater level cannot be so If RPV water level cannot be so main-maintained, maintain Rx water tained, maintain RPV vater level above level above o in, on Post (-164 in. (top of active fuel)).

Accident Flooding Range Instr-menta (top of active fuel) with the above systems.

l JUSTIFICATION OF DIFFERENCE Zero inches on the post accident flooding range instruments is the top of the active fuel. "With the above systems" clarifies the systems to be used.

Page 341 of 378

PSTG STEP EPG STEP C5-2.2 If Rx water level cannot be If RPV vater level cannot be maintained restored and maintained above above (-164 in. (top of active fuel)),

O in. on Post Accident Flood- EMERGENCY RPV DEPRESSURIZATION IS ins Range Instruments (top of REQUIRED:

active fuel), EMERGENCY RX DEPRESSURIZATION IS REQUIRED.

continue in this procedure at step C5-2.2.1. _0therwise, proceed to step C5-3.

4 JUSTIFICATION OF DIFFERENCE O inches on the post accident flooding range instruments is the nominal top of the active fuel. -

Directions are added to clarify which steps should be executed.

Page 342 of 378 , ,

PSTG STEP

1. Stop and prevent all injection into the Rx except from boron injection systems and CRD until Rx pressure is below the Minimum Alternate Rx Flooding Pressure.

MINIMUM' ALTERNATE RX NUMBER OF OPEN SRVs FLOODING PRESSURE (psis)-

6 or more 190 5 210 4 260 3 320 2 440 1 830 EPG STEP

~

C7-2.1 Terminate and prevent all injection into the RPV except from boron injection systems and CRD until RPV pressure is below the Minimum Alternate RPV Flooding Pressure.

MINIMUM ALTERNATE RPV NUMBER OF OPEN SRVs FLOODING PRESSURE (psig)

• 7 or more 155 6 185 5 225 4 285 3 385

._.2 531 _.

JUSTIFICATION OF DIFFERENCE The BFN specific values for Minimum Alternate Rx Flooding Pressure e.re inserted per Appendix C-21.0.

Page 343 of 378 ,

PSTG STEE EPG STEP

2. If less'than one (minimum number If less than (2 (minimum number of SRVs of SRVs for which the Minimum for which the Minimum Alternate RPV Alternate Rx Flooding Pressure Flooding Pressure is below the lowest is below the lowest SRV lifting SRV lifting pressure)] SRVs can be open-pressure) SRV can be opened, ed, continue in this procedure, continue in this procedure.

JUSTIFICATION OF DIFFERENCE The BFN specific value for minimum number of SRV's for which the Minimum Alternate Rx Flooding Pressure is below the lowest SRV lifting pressure per Appendic C-21.0 is inserted.

Page 344 of 378 9

PSTC STEP EPG STEP

3. Commence and, irrespective lf C7-2.2 Commence and slowly l#25l of pump NPSH limits, slowly increase injection into increase injection into the Rx the RPV with the following with the following systems to systems to restore and maintain restore and maintain Rx water RPV water level above (-164 in.

level above 0 in. on Post (top of active fuel)]: Accident Flooding Range Instru-ments (top of active fuel) but

• Condensate /feedwater system as low as practicable. CRD RCIC

                                       -     Condensate /feedwater

• HPCI

                                       -     CRD                                      LPCI RCIC with suction from the CST, defeating low Rx pressure isolation interlocks if necessary
                                       -     HPCI with suction ~from the CST, defeating high suppression pool water level suction transfer logic interlocks 1.'

suppression pool temper-ature is above 140'T

                                       -     LPCI bypassing RHR in-                                     ,

jection valve timers if necessary; place appli-cable RHRSW pump (s) in operation as soon as possible. Page 345 of 378 ,,

JUSTIFICATION OF DIFFERENCE BFN specific action values are inserted. Zero inches on the Post Accident Flooding Range' instruments indicates nominal-top of active fuel. Words are inserted in the PSTG step to perform this action, ' irrespective of pump NPSH limits'. Action to restore and maintain Rx water level above the TAF to assure adequate core cooling take priority over possible damage to pumps due to operation outside of the NPSH limits. Words are added to the PSTG to clarify the step, 'but as low as practicable'. The EPGs and PSTGs call for restoring and maintaining level above TAT following Emergency Ex Depressurization but do not specify a target band. The intent of both is.co maintain level as low as possible but above TAF to limit power production until the reactor is shutdown when level may be restored to normal. PSTG caution 5 corresponds to EPG caution 25. Details of operation are included for RCIC. RCIC is normally lined up to the CST.- The operator is instructed to maintain this suction path. In the event of an ATWS, suppression pool temperatures are likely to be high threatening RCIC operation (NPSH limits or turbine bearing oil temperature). Even if the CST is pumped empty, RCIC lineup to the CST is preferred because auxiliary systems and other temporary means of refilling the CST may be available. The CST has higher quality water also. This argument also pertains to HPCI. Low Rx pressure interlocks are defeated for RCIC because some injection can still be obtained above the turbine stall pressure. This interlock is not required for Tech Specs but is there for equipment protection. In certain degraded conditions it is appropriate to bypass. Because HPCI operation may be threatened if suppression pool temperature exceeds 140*F (T/S bases 3.5E) the operator is dire.cted to bypass the high level suction swapover interlock. This assures operation of HPCI is maintained as long as necessary. EPG caution 4 is implemented in the direction for LPCI operation. Also bypassing the injection valve timers is permitted. This is nccessary since if an accident sigan1 is present, the injection valves are maintained full open for 5 minutes. It is necessary to throttle RHR flow here and bypassing these timers is absolutely necessary. Page 346 of 378 u

PSTG STEP EPG STEP

               ^

4. If Rx vater level cannot be If RPV water level cannot be restored restored and maintained above and maintained above (-164 in. (top of 0 in. on Post Accident Flood- active fuel)], commence and slowly in-ing Range Instruments (top of crease injection into the RPV with the active fuel), commence and, following systems to restore and main-irrespective of pump NPSH tain RPV water level above (-164 in.

limits, slowly increase in- (top of active fuel)]: jection into the Rx with the following systems to restore HPCS and maintain Rx water level

• LPCS above 0 in. on Post Accident
• RHR service water crosstie Flooding Range Instruments
• Fire System (top of active fuel) but as
• Interconnections with other units low as practicable.
• ECCS keep-full systems

      -     CS
      -     Condensate transfer pumps to RHR and CS 0 to 100 psig, O to 1000 gpm
      -     SLC (test tank) augmented by demineralized water head tank 0 to 1400 psig, 23 gpm test tank capacity -

210 gallons demineralized water tank a capacity - 30,000 gallons , makeup available at 23 gpm SLC (boron tank) 0 to 1400 psig, 50 gpm storage tank capacity - 4500 gallons RHR crosstie to other units 0 to 310 psig, O to 5000 gpm

      -     Standby Coolant 0 to 160 psig, O to 3500 gpm
      -     RHR Drain Pumps 0 to 40 psig, O to 600 gpm
      -     PSC Head Tank Pumps 0 to 40 psig, O to 80 gpm Page 347 of 378 e

                               -   RCIC (using cux. b311er steam) aux. boiler steam pressure O'- 250 paig Rx pressure 0 - 350 psis, 600 grJ
                               -   HPCI (using aux. boiler steam) aux. boiler steam pressure 0 - 250 psig Rx pressure 0 - 350 pais, 5000 spa JUSTIFICATION OF DIFFERENCE Zero inches on Post Accident Flooding Range corresponds to nominal TAF.

At this point assdring adequate core cooling takes precedence over preserving equipment by observing NPSH limits. This is clarified in the PSTG by adding words to this effect and meets the intent of the EPG step.

                    'But as low as practicable' is added to the PSTG because it it appropriate to maintain level as low as possible but above TAF, limiting Rx power production until the reactor is shutdown.

HPCS is omitted since BFN does not have this system. The BFN specific Alternate Injection subsystems are listed. r Page 348 of 378 , ,,

                                                                         - - -              ,e-   -

PSTG STEP EPG STEP If while ex$cuting step C5-3 and If while executing the following step associated substeps reactor power reactor power commences-and continues commences and continues to increase, to increase, return to (step C7-1). return to step C5-1. JUSTIFICATION OF DIFTERENCE The applicable step is identified to clarify the procedure. Step C5-1 of the PSTG corresponds to step C7-1 of the EPG. Page 349 of 378

PSTG STEP EPG STE2 C5-3 When 366 pounda (Hot Shutdown C7-3 When (204 pounds (Hot Shutdown Boron Weight) of boron have been Boron Weight)] of boron have been injected, reatore and maintain injected or all control reds are Rx water level between +11 in. inserted beyond position (06 (low level scram setpoint) (masimum suberitical banked and +54 in. (high level trip withdrawal position)], restore setpoint). and maintain RPV water level be-tween (+12 in. (low level scram setpoint)] and (+58 in. (high level trip setpoint)]. JUSTIFICATION OF DIFFERENCE The BFN specific values are inserted for the PSTG. 366 lbs. is the Hot Shutdown Boron Weight per t.ppendix C-24.0. 11 inches is the nominal low level scram setpoint and 54 inches is the nominal high level turbine trip setpoint. The condition on control rod position has been deleted and it handled in the first override in PSTG C5. It is appropriate to exit this procedure at any time the control rods are inserted to or beyond the maximum suberitical banked withdrawal position because this condition assures the reactor will remain shutdown, and it is not necessary to wait until this step. Page 350 of 378

PSTG STEP EPG STEP C5-3.1 If Rx water level cannot be If RPV water level cannot be restored restored and maintained above and maintained above (+12 in. (low.

                 +11 in. (low level scram           level scram setpoint)], maintain RPV setpoint), then me.ir.tain Rx     water level above (-164 in. (top of water level above 0 in on          active fuel)).

Post Accident Flooding Range Instrumenta (top of active fuel). JUSTIFICATION OF DIFFERENCE The BFN specific values have been inserted. Eleven inches is the nominal low level scram setpoint. O inche's on the Post Accident Flooding Ram a corresponds to nominal top of active fuel (TAF). f F Page 351 of 378 , ,, _-~

     ~~-----

PSTG STEP EPG STEP C5-3.2 If Rx water level cannot be If RPV water level cannot be maintained maintained above 0 in, un the above (-164 in. (top of active fuel)), Post Accident Flooding Range EMERGENCY RPV DEPRESSURIZATION IS Instruments (top of active REQUIRED; return to [ step C7-2.1).. fuel), EMERGENCY RX DEPRES-SURIZATION IS REQUIRED; re-turn to step C5-2.2.1. JUSTIFICATION OF DIFFERENCE O inches on Post Accident Flooding' Range corresponds to nominal top of active fuel. Step C5-2.2.1 of the PSTG corresponds to step C7-2.1 of the EPG. Page 352 of 378 ,, ,

n . - . . . - _ . .

                   -PSTG STEP                                       EPG STEP No corresponding step.                        If Alternate Shutdown Cooling is re-quired, enter (procedure developed from CONTINGENCY #5).

JUSTIFICATION OF DIFFERENCE The Alternate Shutdown Cooling procedure is not implemented at 5FN for the reasons discussed in the deviation associated with EPG Contingency 5 (final item in this document). Page 353 of 378 , ,,,

PSTG STEP EPG STEP C5-4 When GOI-100-12 (procedure for C7-4 Proceed to cold shutdown in cooldown to cold shutdown

           ~

accordance.with (procedure for conditions) is entered from the cooldown to cold shutdown condi-procedure developed from the tions). Rx Control Guidelines at step RC/P-5, proceed to cold shut-down in accordance with GOI-100-12 (procedure for cooldown to cold shutdown conditions). JUSTIFICATION OF DIFFERENCE GOI-100-12 is the BFN specific procedure for cooldown to cold shutdown conditions. In the PSTG the' operator is to wait until directed into the procedure from step RC/P-5. After RPV pressure has been reduced to below the shutdown cooling interlocks and the shutdown cooling system has been placed in service, normal operating procedures provide control of Rx water level while proceeding to cold shutdown conditions. Page 354 of 378

PSTG STEP EPG STEP CONTINGENCY'kl CONTINGENCY #4 CORE COOLING WITHOUT LEVEL RESTOR- CORE COOLING WITHOUT LEVEL RESTORATION ATION C7-1 Open.all six ADS valves. C4-1 Open all ADS valves. MM JUSTIFICATION 0" DIFFERENCE Caution 13 is omitted from this scep. See the justification contained in the

                               ' cautions' sectica of this document.

BFN has 6 ADS valves p r unit. PSTG Contingency 7 corresponds to EPG contingency 4. Numbering is done this way to minimize changes when the PSTGs are upgraded to EPG revision 4. Page 355 of 378 , , , ,

PSTG STEP EPG STEP G7-1.1 If ady ' ADS valve cannot be If any ADS valve cannot be opened, opened, open other SRVs until open other SRVs until (7 (number of-six (number of SRVs dedicated SRVs dedicated to ADS)) valves are to ADS) valves are open. open. JUSTIFICATION OF DIFFERENCE BFN has 6 ADS valves per unit. Page 356 of 378 , ,, , w - - - - ~ yw, w y,-. . .-+ - - - w- ---

                                                                         -~v-   y --rc -w w,   1--r~-~--g-*  w rv ---e-7t-t--+-r - - - ' - "      - " - - *    "* ~~

                -PSTG STEP                                                       EPG STEP C7.-2 Operate as many CS pumps as pos-         C4-2 Operate HPCS and LPCS subsystems sible, taking suction from the                          : with suction from the suppression suppression pool and injecting                            pool.

ir.to the Rx. JUSTIFICATION OF DIFFERENCE BFN does not have high pressure core spray system and thus reference to it is omitted. Additional information regarding flow path is provided. Page 357 of 378

4 PSTG STEP EPG STEP G7-2.1 When: When at least one core spray subsystem is operating with suction from the

             - At least one CS subsystem       suppression pool and RPV pressure is is operating with suction       belov [310 psig (RPV pressure for rated from the suppression pool,      LPCS or HPCS flow, whichever pressure and                             is lower)], terminate injection into the RPV from sources external to the
                                                               ~
             - Rx pressure is below 130        primary containment.

psig (Rx pressure for rated CS flow) and

             - reactor water level is maintained at or above -48 inches on the post-acci-dent flooding range instru-ments (two-thirds core height)

Stop injection into the Rx from sources external to the primary containaent. JUSTIFICATION OF DIFFERENCE 130 psig is the BFN Rx pressure for rated core spray flow. The additional condition on Rx water level is added to ensure that adequate core cooling is maintained GE studies (done after EPG revision 3 was approved) indicate for BWR-4 designs that Core Spray by itself does not provide adequate core cooling in a steam environment. If the core water level is at or above two-thirds core height, adequate core cooling is assured. Dage 358 of 378

PSTG STEP EPG STEP A C7-3 When Rx water level is restored C4-3 When RPV water level is restored to 0 in, on Post Accident to [-164 in. (top of active Flooding Instruments (top of fuel)], enter (procedure developed active fuel), enter.the pro- from.the RPV Control Guideline] cedure developed from the Rx at [ step RC/L]. Control Guideline at step RC/L. JUSTIFICATION OF DIFFERENCE O inches on the post accident...'oding range corresponds to nominal top of active fuel. . None of the other instrument ranges include TAF. Page 359 of 378 , , ,

g PSTG STEP EFG STEP No correspodding steps. CONTINGENCY #5 ALTERNATE SHUTDOWN COOLING CS-1 Initiate suppression pool cooling. C5-2 Close the (RPV hea'd vents), main steam line drain valves, and HPCI and RCIC isolation valves. C5-3 Place the control switch for (one (Minimum Number of SRVs Required for Alternate Shutdown Cooling)] SRV(s) in the OPEN position. C5-4 Slowly raise RPV water level to establish a flow path through the open SRV back to the suppression pool. C5-5 Start cne LPCS or LPCI pump with suction. '! rom the suppression pool. C5-6 Slowly increase LPCS or LPCI in-jection into the RPV to the maximum. C5-6.1 If RPV pressure does not stabilize at least (94 psig (Minimum Alternate Shutdown Cooling RPV Pressure)] above suppression chamber pressure, start another LPCS or LPCI pump. C5-6.2 If RPV pressure does not stabilize below (172 psig (Maximum' Alternate Shutdown Cooling RPV Pressure)], open another SRV. Page 360 of 378

PSTG STEP EPG STEP

                                                  .C5-6.3 If the cooldown rate ex-ceeds (100*F/hr (maximum RPV cooldown rate LCO)],

reduce LPCS or LPCI injec-tion into the RPV until the cooldown rate decreases below (100*F/hr (maximum RPV cooldown rate LCO)] (or RPV pressure decreases to within 50 psig (Minimum SRV Re-opening Pressure) of suppression chamber pres-sure, whichever occurs first). C5-7 Control suppression pool tempera-ture to maintain RPV water tem-perature above (70*F (RPV NDTT or head tensioning limit, whichever is higher)]. CS-8 Proceed to cold shutdown in accordance with (procedure for cooldown to cold shutdown con-ditions). JUSTIFICATION OF DIFFERENCE The alternate shutdown cooling procedure is not implemented at BFN. This mode of operation is not part of the BFN FSAR. As indicated by the February 14, 1984 event at BFN, alternate shutdown cooling is not believed to be a good alternate in the event of,a emergency. Whatever system was used to depressurize the reactor would continue to be used. Ba' sed on this operational decision and based on the fact that the MSRVs and discharge devices are not qualified nor tested to assure they can pass saturated liquid (they have been qualified for superheated steam and other tests indicate that subcooled water is acceptable), EPG Contingency 5 is not implemented. Page 361 of 378 , .

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RESPONSE TO HRC CONCERNS EXPRESSED IN THEIR TER ON THE PROCEDURES GENERATION PACKAGE (PGP) Page 370 of 378 ..

CONCERN: The draft PGP lacked comprehensive detail concerning the process used to translate the generic guidelines into the plant specific technical guidelines. RESPONSE: More detail concerning that process has been incorporated in the "PSTG Development" section of the PGP. See pages 6-9 for that information. CONCERN: The draf t PGP lacked comprehensive detail concerning the description / qualification of the persons responsible for the development of the PSTGs. RESPONSE: A description of the types and qualifications of the personnel rasponsible for the development of the PSTGs has been incorporated into the PGP. See page 8 for that information. CONCERN: The PSTG appendices were in draft form and uncontrolled as a plant document. RESPONSE: The PSTG appendices (A, B, C, D) are currently in draft form. Technically, there is very little work required to complete these documents. The plan for controlling these documents is to incorporate them into a document called the "E0I Program Manual". This manual will contain the following documents: PSTGs

              - Appendix A to the PSTGs
              - Appendix B to the PSTGs              -
              -   Appendix C to the PSTGs
              -   Appendix D to the PSTGs
              -   Deviations Cross Reference Document When complete, this document will be controlled in accordance with existing plant, procedures for document revision and control. As such, the initial document and any subsequent changes thereto'will be subject to (among others) QA review and final review by'PORC and approval by the Plant Manager.

CONCERN: EPG step, "Caution 10", omitted the two independent indications required to place ECCS in manual mode. ESSPONSE: This typographical error has been corrected. This material has been added in to Caution 10. See page 143 for this information. i Page 371 of 378 . ,,,

CONCERN: Abbreviations presented in the PSTGs are not consistent with the abbreviations listed in the Writers Guide. RESPONSE: The two abbreviation lists have been modified to be consistent with each other. However, not all entries in each list are in the other due to differences in terminology between the two documents. Refer to pages 119 thru 124 and 125 thru 128 for these two tables. CONCERN: Justification for differences in the Deviations Cross Reference Document do not correspond to the reasons stated in the "PSTG Development" section of the PGP. For example, EPG Caution 10 was deleted for the following reasons:

             "This EPG caution is not contained in the PSTGs because it provides extraneous information. The operators are trained on how to operate ECCS and the guidance in this caution contains no additional, useful information."

The reasons referenced in the "PSTG Development" section are as follows:

                   "Delete all references to systems that do not apply to the Browns Ferry design" "Incorporate plant specific limits, setpoints, and other plant specific data"                               ,

RESPONSE: The "PSTG Development" section of the PGP has been expanded to explain in more detail the process used to develop the PSTGs from the EPGs including an evaluation of the steps and cautions in the EPGs. In this particular instance, this caution was deleted from a later revision of the generic EPGs (revision 4) as being unnecessary and extraneous guidance. The PGP changes discussed can be found on pages 6-7. CONCERN: Plant specific' action levels, setpoints, and curves may be calculated in a-manner other than that specified in the generic guidelines (e.g. the Suppression Pool Load Limit). RESPONSE: Justification for these type deviations have been expanded to include a discussion of the reasons for deviations from the values calculated using the generic calculational procedure. In addition, the bases for these curves (ref. PSTG appendix A) will include a discussion of the methodology used in determining these values. Page 372 of 378 ,, ,,,

CONCERN: It was recommended that only differences that are safety significant be submitted to NRC for review. RESPONSE: NUREG-0899, "Guidelines for the Preparation of Emergency Operating Procedures," specifically states that development of Plant Specific Technical Guidelines should include explanations of deviations between the PSTGs and the EPGs due to "different plant' equipment, operating characteristics, or design." In order to comply with NUREG-0899 we have included deviations that fit the above defined categories and may not be safety significant. CONCERN: The writers guide should state that each page should contain procedure title, revision number, and unit number. RESPONSE: This guidance has been incorporated into the Writers Guide. See section 4.2.1 on page 107 for this information. CONCERN: Writers Guide should address the format of steps used to verify whether the objective of a task or sequence of actions has been achieved. RESPONSE: There is no unique format for steps which verify whether the objective of a task or sequence of actions has been achieved. These determinations are made by use of logic statements and override statements which test for particular conditions and

• direct *the operators as required by existing plant conditions.

See Writers Guide section 4.2.3 on page 109 and section 4.3.8 on page 114 for more information on this subject. CONCERN: Writers Guide should address the format of steps for which a , number of alternative actions are equally acceptable. RESPONSE: The 9 are no steps ter which therr 2 a number of equally act eptable alt'ernative actions. Tuerefore, this comment does not apply. CONCERN: Writers Guide should address the format of steps of a continuous or periodic nature. RESPONSE: There are no steps of a continuous or periodic nature. Therefore, this comment does not apply. Page 373 of 378 , ,_

CONCERN: Writers Guide should address the format of steps performed concurrently with other steps. RESPONSE: Concurrently executed steps conform to the format guidance specified in section 4.2 on pages 107-112. Concurrent actions are specified by an override preceding the first of the steps to be performed concurrently. The format of .this particular type of override step is contained in section 4.2.3.6 of the Writers Guide on page 109. CONCERN: A list of words to use, their definition, and words to avoid should be included in the Writers Guide. RESPONSE: A list of acceptable action verbs, unacceptable action verbs, and words to avoid has been included in the Writers Guide. See attachments 1 and 2 of the Writers Guide on pages 119 thru 124 and 125 thru 128. CONCERN: A list of acceptable abbreviations, acronyms, and symbols should be included in the Writers Guide. RESPONSE: A list acceptable abbreviations and acronyms has been added to the Writers Guide. See attachment 2 to the Writers Guide on pages 125 thru 128. A list of symbols is not included because we do not use any special symbols in our E0Is. CONCERN: Writers Guide should not only ensure that punctuation remains consistent throughout a procedure, but that punctuation is consistent between procedures. RESPONSE: This guidance has been incorporated into the Writers Guide in section 4.3.2 on page 112. CONCERN: The Writers Guide discussion on numerical values did not include a discussion on how decimals and cignificant figures are to be handled. RESPONSE: Parameter precision required should be consistent with the precision available on the instrument being used to read that paramete.r. Setpoint values may exceed the precision available on instruments or displays if the setpoint denotes an alarm value or the initiation of an automatic action. Further information on numerical values and units can be found in section 4.3.6 of the Writers Guide on pages 113-114. We feel no additional information is necessary. Page 374 of 378 , ,

   ,   ,, _       . .  .                . - _.     -    -           - = - . - -   .   . .  . . -

t CONCERN: A requirement'for consistency between terminology and nomenclature on-the instrumentation, controls,'and panels and the E0Is'should be included-in the Writers Guide. RESPONSE: This ,information has been incorporated into .the Writers Guide. See section 4.3.5 on page 113. CONCERN: " The Writers Guide should direct the writer to use tables or graphs in lieu of calculations where possiole. RESPONSE: This information has been incorporated into the Writers Guide. See section 4.3.7 on page 114. CONCERN: Writers Guide should be expanded to include definitions of logic terms, examples of acceptable combinations, and examples of combinations to avoid. RESPONSE: This information has been incorporated into the Writers Guide. See section 4.3.8 on pages 114-115. CONCERN: The Writers Guide should specify that the number of procedures being executud concurrently not exceed the capability of the

                          ' control room staff to manage.

RESPONSE: This information has been incorporated into the Writers Guice. See section 4.4.1 on~page 115. CONCERN: The Writers Guide should contain a speelfic guideline on the content and format of the phrase used to reference another procedure or section of a procedure. Further, the method of identifying sections or subsections should be described. RESPONSE: We do not feel it necessary to incorporate specific guidance as to the content an'd format of the reference phrase. They adhere to the same guidelines already contained in the Writers Guide. The E0I sections referenced are identified by tabs in the five ' section binder. CONCERN: The use of initials in the E0Is should be avoided. RESPONSE: We do not feel it necessary to incorporate any additional guidance on the use of initials. This information is currently contained in section 4.3.4 of the Writers Guide on page 113. We feel the guidat.a in this section is explicit enough to preclude includine, any additional material on the use of initialn. I Page 375 of 378 - . . . ek-

CONCERN The Writsrc Guide did not addrsac the availability and accessibility of the E0Is and the techniques used to distinguish them from other procedures. RESPONSE: This information is currently contained in the approved site procedure dealing with implementation and maintenance of the E0Is. This guidance will be incorporated into the PGP cn page 12. CONCERN: The PGP did not explicitly state that the Writers Guide will be precisely followed by the E0I writers and used in developing and revising the E0Is. RESPONSE: This material will be incorporated into the PGP in page 14. CONCERN: Need to specify in more detail under what circumstances each validation method will be employed. RESPONSE: Additional information has been added to the "E0I Validation Program" section of the PGP on page 23. CONCERN: No provision was noted in validation activities for persons skilled in Human Factors Engineering, even though a specific objtetive of the activity is a determination of correspondence between procedures and control room hardware. RESPONSE: Ha're incorporated a statement in the "E0I Validation Program" section of the PGP concerning the use of human factors personnel in the validation. See page 21 for this information. CONCERN: If the Table-Top method of validation is used, some type of mock-up or plant drawings must be provided to assure a womparison of the E01 to control room hardware issue is able to be resolved. The licensee advised the NRC auditors that a Table-Top must'be followed by a control rooa walkthrough or simulator run, but this provision was not included in the procedures reviewed. RESPONSE: Additional material concerning this issue has been added to the PGP on page 23. Page 376 of 378

f CONCERN: Instrument and control details (such as resolution) were absent from the criteria checklist used to evaluate performance during the validation. RESPONSE: Although the word ' resolution' is not specifically used in the checklist, certain items in the "Plant Compatibility" section of the checklist are used to determine if control room instrumentation is adequate to support the procedures being validated. We do not feel that any additional information is necessary. CONCERN: Details were not included on treatment of unit differences in either verification or validation. RESPONSE: Verification ensures tnat the E0Is conform to the Writers Guide and the PSTGs. These documents apply to all three units. There are no differences between the units with regard to the Writers Guide and the PSTGs (except one set of instruments that differs , from Unit 2 to units 1, 3). Therefore, with respect to verification, we do not feel any additional information needs to be provided discussing unit differences. With respect to validation, additional material has been incorporated into the PGP at page 22. CONCERN: The program description did not include a description of the criteria that will be used to select the scenarios to be run during the validation process, including those parts of the E0Is that cannot be validated on the simulator. RESPONSE: This information has been incorporated into the PGP section entitled "Scenario Selection" on page 24. CONCERN: The description of the training program did not contain the objectives to be achieved by the training of operators to use the E0Is. RESPONSE: The objectives are now included in the PGP under the section describing the training program on page 27. CONCERN: The training program description did not address the method to be used to train the operators in areas where the simulator does not react like the plant and in parts of the EDIs that cans:ot be run on the simulator. RESPONSE: Additional information has been added in the PGP to address this issue. Refer to page 31. Page 377 of 378 . ..

7 CONCERN: The training program description did not address the use of the simulator as team training and for previously planned operator roles. RESPONSE: This material has been incorporated in the section of the PGP discussing the training program on page 31. CONCERN: The training program description did not address the use of a wide variety of scenarios including multiple (simultaneous and sequential) failures, to fully exercise the E0Is on the simulator and thus expose the operators to a wide variety of E0I uses. RESPONSE: This material has been incorporated in the section of the PGP discussing the training program on page 29. CONCEEN: The training program description did not address the extent that the E0Is will be covered by all operators, particularly if the walk *.hroughs will be used te train aspects of E0Is not taught on the simulator. RESPONSE: This issue is addressed in the "Training Program" description section of the PGP on page 27. CONCERN: The training program description did not address the use of a walkthroughs as team training and to train previously planned operator roles. RESPONSE: This material is covered in the "E0I Training Program" section of the PGP beginning on page 27. i CONCERN: The training program description did not address the use of a wide verify of scenarios to fully exercise the E0Is during the walkthroughs. *

• RESPONSE: These walkthroughs are not for validation. They are walkthroughs for the purpose of familiarization of the operators. Scenarios are not run during these walkthroughs.

Page 378 of 378 , ,,,

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