CNL-13-126, Proposed Technical Specification Change to Revise the Leakage Rate Through MSIVs-TS-485

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Proposed Technical Specification Change to Revise the Leakage Rate Through MSIVs-TS-485
ML14015A403
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 11/22/2013
From: James Shea
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-13-126, EA-11-252
Download: ML14015A403 (40)
v • d • e


Text

L44 131122 0 Attachment 5 of Enclosure 1 contains proprietary information and should be withheld from public disclosure under 10 CFR 2.390. Upon removal of the proprietary information, this letter is decontrolled.

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-13-126 November 22. 2013 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Browns Ferry Nuclear Plant Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259. 50-260, and 50-296 Subject Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Proposed Technical Specification Change To Revise The Leakage Rate Through MSIVs -

TS-485

Reference:

Letter from TVA to NRC, "Updated Reply to Notice of Violation; EA-:1 1-252; and Follow-up to 10 CFR 50.9. 'Completeness and accuracy of information,'

Notification," dated August 30, 2013 In accordance with the provisions of Title 10 of the Code of Federal Regulations (CFR) 50.90, "Application for Amendment of License. Construction Permit, or Early Site Permit," the Tennessee Valley Authority (TVA) is submitting a request for a Technical Specification (TS) amendment (TS-485) to Renewed Facility Operating License Nos.

DPR-33, DPR-52, and DPR-68 for Browns Ferry Nuclear Plant (BFN) Units 1. 2, and 3.

respectively, to decrease the allowable leakage rate criteria for the Main Steam Isolation Valves (MSIVs).

The TVA is proposing changes to BFN, Units 1, 2, and 3, TS 3.6.1.3, "Primary Containment Isolation Valves (PCIVs)," to reduce the individual and total leakage rate through the MSIVs In the Reference letter, the Alternative Leakage Treatment (ALT) Pathway was identified as being in a non-conforming/degraded condition. The corrective actions that were outlined to change the ALT Pathway included modification of licensing documents to show lower individual and total leakage rates through the MSIVs.

The date to submit this license amendment request was November 21. 2013, in accordance with a commitment in the Reference letter. On November 21, 2013, during a telephone conversation. Mr. Jesse F. Quichocho, Chief, Plant Licensing Branch 11-2, Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation, acknowledged the one day delay in meeting the commitment contained in the Reference letter.

U.S. Nuclear Regulatory Commission Page 2 November 22, 2013 The enclosure provides a description of the proposed changes, technical evaluation of the proposed changes, regulatory evaluation, and a discussion of environmental considerations.

Attachments 1 and 2 to Enclosure 1 provide the existing TS and Bases pages marked-up to show the proposed changes. Attachments 3 and 4 to Enclosure 1 provide the existing TS and Bases pages retyped with the proposed changes incorporated. The Bases pages are being provided for information only. to this letter contains information which WorleyParsons Polestar, Inc.

considers to be proprietary in nature and subsequently, pursuant to 10 CFR 2.390, "Public-inspections, exceptions, request for withholding," paragraph (a)(4), it is requested that such information be withheld from public disclosure. Attachment 11 provides the affidavit supporting the request. Attachment 6 contains the redacted version of the proprietary attachment with the proprietary material removed, which is suitable for public disclosure.

The TVA requests approval of this TS change by November 22, 2014. TVA also requests an implementation date of February 21, 2015.

The TVA has determined that there are no significant hazards considerations associated with the proposed change and that the TS change qualifies for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9). Additionally, in accordance with 10 CFR 50.91 (b)(1), the TVA is sending a copy of this letter, the enclosure, and the non-proprietary attachments to the Alabama State Department of Public Health.

The BFN Plant Operations Review Committee has reviewed this proposed change and determined that operation of BFN in accordance with the proposed change will not endanger the health and safety of the public.

There are two regulatory commitments associated with this submittal. as described in .

If there are any questions or if additional information is needed, please contact Mr. Tom Hess at (423) 751-3487.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2 2 nd day of November 2013.

Res tfully J..

ce tNuclear Licensing

Enclosures:

cc: See Page 3

U.S. Nuclear Regulatory Commission Page 3 November 22, 2013

Enclosures:

1. TS-485, Alternate Leakage Treatment (ALT) Pathway Attachments
1. Proposed Technical Specifications Pages Markups
2. Proposed Technical Specifications Bases Pages Markups (for information only)
3. Proposed Retyped Technical Specifications Pages
4. Proposed Retyped Technical Specifications Bases Pages (for information only)
5. NDQ099920010019 (proprietary), "Ex-Containment Removal Coefficients for Alternative Source Term Analyses"
6. NDQ099920010019 (non-proprietary), "Ex-Containment Removal Coefficients for Alternative Source Term Analyses"
7. NDQ0031920075, "Control Room and Offsite Doses Due to a LOCA"
8. NDQ0999980016, "Parameters Used in Dose Analyses"
9. CDNO001990113, "Seismic Evaluation Report"
10. Proposed Updated Final Safety Analysis Report Page Markups
11. Affidavit
2. List of Regulatory Commitments cc (Enclosure):

NRC Branch Chief- Region II NRC Project - Browns Ferry Nuclear Plant State Health Officer, Alabama State Department of Health ECM

ENCLOSURE 1 TS-485 Alternate Leakage Treatment (ALT) Pathway

ENCLOSURE 1 TS-485 Alternate Leakage Treatment (ALT) Pathway 1.0

SUMMARY

DESCRIPTION .................................................................................... E1-2 2.0 D ETA ILED D ESC R IPTIO N .......................................................................................... E1-2 2.1 Proposed C hanges .............................................................................................. E1-2 2.2 Condition Intended to Resolve ............................................................................. E11-3 2.3 Explanation of C ircum stances .................................................................................. E1-3 3.0 TEC HN ICA L EVA LUATIO N ......................................................................................... E 1-5 3.1 S ystem D escription ................................................................................................... E 1-5 3.2 T echnical Analysis .................................................................................................... E 1-5

4.0 REGULATORY EVALUATION

.................................................................................. E1-13 4.1 Applicable Regulatory Requirements/Criteria ......................................................... El-13 4 .2 P re ced e nt ............................................................................................................... E 1-14 4.3 Significant Hazards Consideration ......................................................................... E1-14

5.0 ENVIRONMENTAL CONSIDERATION

..................................................................... E1-16 6.0 R E FE R E NC E S ........................................................................................................... E 1-16 F ig u re 1 ................................................................................................................................. E l-1 8 F ig u re 2 ................................................................................................................................. E 1-1 9 F ig u re 3 ................................................................................................................................. E 1-2 0 ATTACHMENTS

1. Proposed Technical Specifications Pages Markups
2. Proposed Technical Specifications Bases Pages Markups (for information only)
3. Proposed Retyped Technical Specifications Pages
4. Proposed Retyped Technical Specifications Bases Pages (for information only)
5. NDQ099920010019 (proprietary),"Ex-Containment Removal Coefficients for Alternative Source Term Analyses"
6. NDQ099920010019 (non-proprietary),"Ex-Containment Removal Coefficients for Alternative Source Term Analyses"
7. NDQ0031920075, "Control Room and Offsite Doses Due to a LOCA"
8. NDQ0999980016, "Parameters Used in Dose Analyses"
9. CDN0001990113, "Seismic Evaluation Report"
10. Proposed Updated Final Safety Analysis Report Page Markups
11. Affidavit El-1

1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Renewed Facility Operating License Nos.

DPR-33, DPR-52, and DPR-68 for Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3, respectively. The proposed change will make the current passive secondary Alternate Leakage Treatment (ALT) Pathway be the primary pathway and decrease the leakage rates from 100 standard cubic feet per hour (scfh) per valve to 60 scfh for individual Main Steam Isolation Valves (MSIVs) and the combined leakage rates for all four main steam lines from 150 scfh to 85 scfh (References 5 and 6).

2.0 DETAILED DESCRIPTION 2.1 Proposed Changes Changes to BFN, Units 1, 2, and 3, Technical Specification (TS) 3.6.1.3, "Primary Containment Isolation Valves (PCIVs)" are being proposed to decrease the leakage rate through each MSIV and the combined leakage rate through all four main steam lines.

Surveillance Requirement (SR) 3.6.1.3.10 changes The current BFN Units 1,2, and 3, SR 3.6.1.3.10 states:

Verify leakage rate through each MSIV is < 100 scfh and that the combined leakage rate for all four main steam lines is < 150 scfh when tested at > 25 psig.

The Tennessee Valley Authority (TVA) is proposing to change BFN, Units 1, 2, and 3, SR 3.6.1.3.10 to state:

Verify leakage rate through each MSIV is < 60 scfh and that the combined leakage rate for all four main steam lines is < 85 scfh when tested at > 25 psig.

Mark-ups of the affected TS pages are provided in Attachment 1. Corresponding changes are also proposed for the TS Bases. Mark-ups of the proposed TS Bases changes are provided in Attachment 2 for information only. Corresponding proposed Updated Safety Analysis Report (UFSAR) changes are provided in Attachment 10.

Changes to Credited ALT Pathway The primary ALT Pathway is proposed to be defined as the passive pathway through the orifice bypass lines around each of the main steam drain lines, through open valve FCV-1 -57, through the orifice bypass line around valve FCV-1 -58, and finally through a non-orifice bypass line around valve FCV-1 -59 to the condenser (Figure 1). The secondary ALT Pathway is proposed to be the pathway through normally open valves FCV-1-168, FCV-1-169, FCV-1-170, and FCV-1-171, and continues through valves FCV-1-57, FCV-1-58, and FCV-1-59 to the main condenser (Figure 2). The use of a passive pathway as the primary ALT Pathway will result in more than a minimal increase in calculated dose consequences.

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2.2 Condition Intended to Resolve As discussed in a letter to the NRC dated August 30, 2013 (Reference 1), TVA identified that information previously provided to the NRC in certain BFN license amendment requests (LARs) and associated responses to the NRC requests for additional information (RAIs) for the ALT Pathway was incomplete.

To resolve this issue, TVA proposes to take the following actions:

  • Change the current ALT primary flow path to become the ALT secondary flow path.
  • Change the current ALT secondary flow path to become the ALT primary flow path.
  • The maximum leakage from any one MSIV will be decreased from 100 scfh to 60 scfh.
  • The total allowable MSIV leakage rate will be decreased from 150 scfh to 85 scfh.
  • The dose analysis of record will be revised to include the new ALT primary flow path.

2.3 Explanation of Circumstances On September 4, 2012, as part of the ongoing extent of condition reviews responding to Notice of Violation EA-1 1-252 (Reference 10), TVA determined that information previously provided to the NRC in certain BFN LARs and associated responses to the NRC RAIs for the ALT Pathway was incomplete. A 10 CFR 50.9(b) notification was made to the NRC within two working days of discovery.

The ALT Pathway was credited by TVA in NRC submittals to increase MSIV leakage acceptance criteria and to allow use of Alternative Source Term (AST). The submittals containing information that was determined to be incomplete are as follows.

" The MSIV leakage acceptance criteria increase submittals for BFN, Units 2 and 3, dated September 28, 1999 (Reference 2) and February 4, 2000 (Reference 3).

  • The MSIV leakage acceptance criteria increase submittal for BFN, Unit 1, dated July 9, 2004 (Reference 4).

" The AST submittal for BFN, Units 1, 2, and 3, dated August 24, 2004 (Reference 5).

The NRC Safety Evaluation Report (SER) for NEDC-31858P, "BWROG Report for Increasing MSIV Leakage Rate Limits and Elimination of Leakage Control Systems" (Reference 6), required the following to be addressed.

"In parallel to the plant-specific reviews conducted in the past, the staff determined that all licensees referencing the generic report should provide assurance for the reliability of the entire ALT Pathway, including all of its boundary valves. The licensees should also provide assurance that valves required to open the ALT path to the condenser are provided with highly reliable power sources, and that a secondary path to the condenser with orifice flow exists. In addition, valves which are required to open the ALT path to the condenser are to be included in the plant's Inservice Testing (IST) program."

TVA submittals dated September 28, 1999 (Reference 2) and July 9, 2004 (Reference 4) addressed compliance with NEDC-31858P and the associated SER (Reference 6) and stated that valves in each of the four drain lines from the main steam lines (flow control E1-3

valve Main Steam Line A Drain Isolation Valve (FCV-1-168), Main Steam Line B Drain Isolation Valve (FCV-1-169), Main Steam Line C Drain Isolation Valve (FCV-1-170), and Main Steam Line D Drain Isolation Valve (FCV-1-171)) are normally open motor operated valves (MOVs) that would remain open on loss of offsite power (LOOP).

However, these submittals should have also stated that if any MSIV is closed and turbine speed is greater than 1700 revolutions per minute (rpm), these valves would close and would only reopen after turbine speed drops below 1700 rpm.

As a result, TVA submittals failed to address the following:

  • Reliability of power sources for these valves. Valves FCV-1-168, FCV-1 -169, FCV-1-170, and FCV-1-171 are powered from non-safety related MOV boards that do not have emergency diesel generator (EDG) back-up power supplies.

" Reliability of valve logic to reopen the valves to establish the ALT Pathway.

  • The need to include these valves in the IST Program.

TVA submittals dated September 28, 1999 (Reference 2) and July 9, 2004 (Reference 4) stated that two valves in the piping line downstream of the four main steam line drain lines prior to the condenser (Main Steam Drain to Condenser Isolation Valves (FCV-1-58 and FCV-1-59)) are normally closed valves which would require operator action to align the ALT path to the condenser. These TVA submittals also stated that these two valves are powered from essential power buses with EDG back-up and to further ensure valve reliability, these valves would be included in the IST program and periodically stroke tested. One of the valves (FCV-1-59) has a four-inch bypass containing no valves or orifices. Therefore, there is no concern associated with FCV-1-59 with respect to ALT Pathway availability. TVA submittals dated July 9, 2004 (Reference 4) and August 24, 2004 (Reference 5) also stated that valves FCV-1 -58 and FCV-1-59 are designed to be available during and after a Loss of Coolant Accident (LOCA) event concurrent with a LOOP. However, the Units 2 and 3 Reactor MOV boards that powers FCV-1-58 are not qualified for the post-LOCA environment, e.g., temperature, and the Unit 3 Reactor MOV board is also required to be manually loaded onto the associated EDG. As a result, the previous TVA submittals failed to adequately address the reliability of the power source for FCV-1-58 after a LOCA.

TVA submittals dated September 28, 1999 (Reference 2), February 4, 2000 (Reference 3), July 9, 2004 (Reference 4), and August 24, 2004 (Reference 5), indicate that a secondary orifice contingency path is provided in the unlikely event of a failure of the normally closed valve without the four-inch bypass line (FCV-1-58) in the piping downstream of the four main steam line drain lines prior to the condenser. In these submittals, the secondary ALT Pathway consisted of orifice bypass lines around each of the four drain lines (FCV-1 -168, FCV-1 -169, FCV-1 -170, and FCV-1 -171) from the main steam lines through a normally open valve (FCV-1-57), in the piping line downstream of the four main steam line drain lines and then through an orifice bypass line around a normally closed valve (FCV-1-58) and finally through a non-orifice four-inch bypass line around another closed valve (FCV-1-59) to the condenser. These TVA submittals also stated that with the 0.1875 inch orifice path around FCV-1-58, the majority of MSIV leakage would still be directed to the condenser with a smaller remainder through the closed main steam stop and control valves to the high pressure turbine. However, no TVA calculation was found that supports the statement regarding the 0.1875 inch orifice.

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The ALT Pathways have been re-evaluated to resolve these issues and it has been determined that the primary pathway should be through the orifice bypass lines around each of the four drain lines, through valve FCV-1 -57 (which will have its power removed), through the orifice bypass line around valve FCV-1-58, and finally through a non-orifice four-inch bypass line around valve FCV-1 -59 to the condenser. (This was previously the secondary pathway.) The secondary pathway should be through the four drain line valves (FCV-1-168, FCV-1-169, FCV-1-170, and FCV-1-171), valve FCV-1-57, valve FCV-1-58, and valve FCV-1 -59 to the condenser. (This was previously the primary pathway.)

Furthermore, TVA has re-performed the dose analysis to include the new ALT primary flow path that increases the flow bypassing the condenser. The revised dose analysis also assumes decreased individual and total allowable MSIV leakage rates.

3.0 TECHNICAL EVALUATION

3.1 System Description

There are four steam lines installed on each BFN unit and each line is provided with dual quick-closing MSIVs. These valves serve to isolate the reactor coolant system in the event of steam line breaks outside primary containment, a design basis LOCA, or other events requiring containment isolation. For a detailed discussion of the system components and operating characteristics, refer to Section 4.6.3 of the BFN UFSAR.

For a steam line break outside primary containment, the MSIV isolation function prevents damage to the fuel barrier by limiting the loss of reactor coolant. For the LOCA event, the MSIVs limit the release of radioactive materials by closing the primary containment barrier to contain a leak from the nuclear system.

The main steam drain lines are used to preferentially direct MSIV leakage to the main condenser. This drain path takes advantage of the large volume of the steam lines and condenser to provide holdup and plate-out of fission products that may leak through the closed MSIVs. In this approach, the main steam lines, main steam drain piping, and the main condenser are used to mitigate the consequences of an accident. The use of the ALT Pathways to mitigate the consequences of an accident was approved for BFN in License Amendment Nos. 263 (for Unit 2) and 223 (for Unit 3), dated March 14, 2000, and License Amendment No. 261 (for Unit 1), dated September 27, 2006.

3.2 Technical Analysis TVA proposes to continue to utilize the main steam drain lines to preferentially direct MSIV leakage to the main condenser. However, to resolve issues identified in the 10 CFR 50.9(b) notification associated with the ALT Pathways, the primary ALT Pathway (Figure 1) will be defined as the passive pathway through the orifice bypass lines around each of the main steam drain lines, through open valve FCV-1-57, through the orifice bypass line around valve FCV-1-58, and finally through a non-orifice bypass line around valve FCV-1-59 to the condenser. To support the use of this passive pathway, the dose analysis has been re-performed assuming reduced MSIV leakage rates of 60 scfh maximum through each MSIV and 85 scfh for the combined leakage rate for all four main steam lines. The secondary ALT Pathway (Figure 2) has now been defined as the E1-5

pathway through the main steam drain lines and through open valves FCV-1-57, FCV-1 -58, and FCV-1-59 to the condenser.

Detailed Description of ALT Pathways to Condenser The MSIV Seismic Verification Walkdown Boundary (Figure 3) provides a flow diagram schematic that shows the ALT Pathway from the MSIVs to the condenser and the boundary valves associated with the ALT Pathway for BFN, Units 1, 2, and 3. As discussed in NEDC-31858P, "BWROG Report for Increasing MSIV Leakage Rate Limits and Elimination of Leakage Control Systems," the ALT Pathway establishes a seismically rugged route to contain and direct leakage from the MSIVs to the condenser following a design basis LOCA.

The primary ALT Pathway is based on the flow path through the orifice bypass lines around each of the main steam drain lines, through open valve FCV-1-57 (which will have its power removed), through the 0.1875-inch orifice bypass line around valve FCV-1-58 and the four inch bypass line around FCV-1-59 for those events taking credit for the availability of the ALT Pathway to the condenser. The primary flow path from the MSIVs to the condenser continues to be passive, requiring no operator actions or valve positions to change to establish the pathway. This primary flow path consists of the following:

  • Four outboard MSIVs through 24- inch lines connecting to two-inch drain lines from each MSIV.
  • Four two-inch bypass lines, that contain 0.25-inch orifices (around valves FCV-1-168, FCV-1-169, FCV-1-170 and FCV-1-171), connecting to a three-inch header.
  • The three-inch header through normally open, with power removed, valve FCV-1 -57 to a three-inch tee.
  • The three-inch tee through a one-inch bypass line (around the normally closed valve FCV-1-58) that has a 0.1875-inch orifice and a normally open manual blowdown valve (BOV)-525.

" A four-inch bypass line (around normally closed valve FCV-1-59) to the condenser.

In the unlikely event the primary flow path is not available, and consistent with the guidance provided in NEDC-31858P, a secondary flow path is provided (although not with orifice flow). The secondary flow path is through normally open valves FCV-1-168, FCV-1-169, FCV-1-170, and FCV-1-171, and continues through valves FCV-1-57, FCV-1-58, and FCV-1-59 to the main condenser.

The primary ALT Pathway, from the outboard side of the MSIVs through orifice lines to the condenser, does not satisfy the sizing requirements of NEDC-31858P.

Paragraph 6.1.1(2) of NEDC-31858P states that the ALT flow path, based on the radiological dose methodology, should be at least one square inch in internal cross sectional area due to the orificed bypass lines. The actual internal cross sectional area of the orificed bypass line around FCV-1-58 is 0.0276 square inches. However, the radiological dose analysis has been performed assuming the orificed pathway and demonstrated acceptable control room dose results and offsite dose results assuming the reduced MSIV leakage rates included in this LAR. The secondary ALT Pathway satisfies the sizing requirements of NEDC-31858 paragraph 6.1.1(2), but does not E1-6

include orifices as described in Section 5.3 of the NRC SER for NEDC-31858P (Reference 6).

Reliability of the ALT Primary Pathway and Boundary To establish the primary ALT Pathway to the condenser, no operator actions are required because this pathway is passive and requires no valve position to be changed to establish the flow path from the MSIVs to the condenser.

The primary ALT Pathway is through this 0.1875-inch orifice with valve FCV-1-58 closed.

The radiological dose analysis associated with primary ALT Pathway has been performed assuming the orificed pathway and demonstrated acceptable control room dose results and offsite dose results. To ensure the flow through the 0.1875-inch orifice is not obstructed, periodic radiography inspection of the 0.1875-inch orifice will be performed during refueling outages. In addition, the Main Steam Stop and Control Valves are included in the preventative maintenance program. As such, one Main Steam Stop and one Control Valve is refurbished each outage. These valves are also tested each refueling outage for leak tightness and are highly reliable.

As previously noted, Figure 3 provides a flow diagram that shows the ALT leakage pathway from the MSIVs to the condenser, and the boundary valves. All boundary valves are either closed during normal system operation or fail closed upon loss of power, loss of control air, or hydraulic pressure or close upon line depressurization. All of the boundary valves fall into one of the following categories:

  • Manual isolation valves that are normally closed.
  • Motor operated valves that are normally closed.
  • Air operated valves that are normally open, but fail closed on loss of power, loss of air, or loss of control signal.
  • Valves isolated by a spring assisted in-line check valve, that have an opening pressure in excess of the ALT drain path differential pressure once the MSIVs have closed and the line has depressurized.

However, during abnormal operations, some boundary valves would be moved from their normal position and therefore would be verified closed as needed to implement the ALT flow path lineup (e.g., PCV-1-147).

The piping and components within the boundaries of the ALT Pathway are included in the BFN IST and Inservice Inspection (ISI) programs, and, accordingly, will be inspected and tested in accordance with the IST and ISI programs. The IST program will test the power operated valves within the ALT Pathway on a periodic basis. The specific test requirements will be based on the function of the individual valve (e.g., passive versus active). All valves included in the ALT Pathway or boundary are included in the IST or Augmented IST Programs. In addition, the functionality of the ALT path has been made highly reliable through the efforts to ensure the line is seismically rugged as discussed in previous submittals for the ALT Pathways (References 2, 3, and 4). To help ensure valve reliability, boundary valves that may be required to close to establish the ALT Pathway boundary are included in the IST program and are periodically stroke tested.

The ALT Pathway and boundary piping has not been included in the augmented Intergranular Stress Corrosion Cracking weld inspection program because it does not E1-7

meet the criteria for inclusion. However, this piping is included in the Flow Accelerated Corrosion program that periodically monitors pipe wall thickness degradation.

Reliability of the Secondary ALT Pathway Valves FCV-1-168, FCV-1-169, FCV-1-170, and FCV-1-171 are normally open MOVs that would remain open in the event of a LOCA concurrent with a loss of off-site power.

However, if any MSIV is closed and turbine speed is greater than 1700 rpm, valves FCV-1-168, FCV-1-169, FCV-1-170, and FCV-1-171 close and reopen after turbine speed drops below 1700 rpm, if power is available. These valves are powered from non-safety related MOV boards that do not have EDG back-up power supplies.

However, the likelihood of a LOOP occurring prior to the valves reopening is considered small. To ensure valve reliability, valves FCV-1-168, FCV-1-169, FCV-1-170, and FCV-1-171 are included in the IST Program and are periodically stroke tested.

Valve FCV-1-57 is normally open, and will have the power removed, to ensure it remains open. Valves FCV-1-58 and FCV-1-59 are normally closed valves, which would require operator action to align the secondary ALT Pathway to the condenser. These two valves are powered from non essential, Class 1 E, Seismic Class 1 Reactor MOV Boards. Units 1 and 2 FCV-1-57 and 58 are not load shed upon LOOP that results in automatic emergency diesel generator back-up availability. Unit 3-FCV-1-57 and 3-FCV-1-58 are also powered from a non essential, 1 E, Seismic Class 1 Reactor MOV Board. However, these Unit 3 FCVs are load shed upon LOOP with emergency diesel generator back-up enabled for manual breaker closure after 40 seconds or the breaker would auto close in 11 minutes. To ensure valve reliability, FCV-1 -58 and FCV-1 -59 are in the IST program and will be periodically stroke tested. However, as stated above, FCV-1-59 has an open full bypass line; therefore, its operation is not essential to align the secondary ALT Pathway based on MSIV leakage of saturated vapor continuing to the condenser through the fully bypassed line.

The Units 1, 2 and 3 Reactor MOV boards and cabling for valves FCV-1-57, FCV-1 -58, and FCV-1-59 do not meet EQ requirements.

The most limiting single active failure for the secondary ALT Pathway is the failure of valve FCV-1-58 to open. In this condition, MSIV leakage flow would be diverted through the one-inch orifice bypass line around valve FCV-1-58 and through normally open manual valve BOV-1-525. With the 0.1875-inch orifice in this one-inch line, it is calculated that 48.9% of the MSIV leakage would be directed to the condenser with the remainder through the closed Main Steam Stop and Control Valves to the high pressure turbine and then to the turbine building.

Valves FCV-1-168, FCV-1-169, FCV-1-170, FCV-1-171, FCV-1-57, FCV-1-58, and FCV-1 -59 were considered for inclusion in the augmented MOV test programs required by Generic Letter (GL) 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance," and GL 96-05, "Periodic Verification of Design-Basis Capability of Safety-Related Power-Operated Valves." The design basis for establishing the ALT Pathway is a LOCA with assumed major core damage and the MSIVs closed. With the MSIVs closed, the ALT Pathway boundary is physically isolated from the reactor vessel and primary containment except through leakage through the MSIVs. In order to establish the primary ALT Pathway, no valves are required to change state. In order to establish the secondary ALT Pathway, valves FCV-1-168, FCV-1-169, FCV-1-170, FCV-1-171, E1-8

FCV-1 -58, and FCV-1-59 may change state, but would not have to change state against a large differential pressure because the post-accident conditions would be less severe than the conditions in which these valves are tested during normal power operations.

Therefore, FCV-1-168, FCV-1-169, FCV-1-170, FCV-1-171, FCV-1-58, and FCV-1-59 are not included in the GL 89-10/96-05 MOV programs because the periodic IST program testing on these valves are considered to be adequate to ensure their functionality. For valve FCV-1 -57, this valve is normally open, and will have the power removed, and therefore it is not included in the GL 89-10/96-05 MOV programs.

Dose Analysis Summary and Results The AST dose calculations (Attachments 5, 6, 7, and 8) have been updated to account for a change to the primary alternate leakage path to the condenser. The purpose of this change is to utilize the orificed flow path to the condenser, currently licensed as the secondary alternate leak treatment flow path, as the primary flow path for alternate leak treatment. Using the orificed flow path as the primary flow path provides a passive pathway to the condenser, which, unlike the previous primary pathway, does not require the manipulation of valves to establish a flow path to the main condenser.

Because the new primary ALT Pathway has a smaller cross-sectional flow area than the previous pathway, the fraction of MSIV leakage that bypasses the main condenser increases. The previous flow area percentage of the primary alternate leak pathway to the condenser bypass pathway was 99.5% to 0.5%. The new flow area percentage of the primary alternate leak pathway to the condenser bypass pathway is 48.9% to 51.1 %.

The 48.9% of the MSIV leakage directed to the condenser is based on a ratio of 0.0288 in2 (Generic Flow Area to the High Pressure Turbine due to leakage through the Main Steam Stop Valves) and 0.0276 in2 (0.1875-inch orifice Flow Area of the credited Drainline Pathway). MSIV leakage is being reduced from 150 scfh total and 100 scfh maximum per line to 85 scfh total and 60 scfh maximum per line to partially compensate for this increased main condenser bypass.

Aerosol and elemental iodine removal, due to sedimentation and diffusion respectively, are credited in the main steam lines and in the main condenser. The increased main condenser bypass and reduced MSIV leakage result in changes in aerosol and elemental iodine removal coefficients in the steam lines and main condenser. The methodology used is the same as currently approved by the NRC and is outlined below.

The analysis assumes that three of the four steam lines are isolated and intact up to the turbine stop valves, while in the remaining steam line, the inboard MSIV is assumed to be failed open. For the three steam lines that are isolated and intact, sedimentation occurs in the steam lines from the vessel up to the turbine stop valves. However, only the piping between the inboard MSIV and the point where the drain line taps off to go to the main condenser is credited for removal of activity. This piping is divided into two adjacent volumes: (1) the volume between closed MSIVs, and (2) the volume between the outboard MSIV and the point where the drain lines tap off to go to the conderdser. As for the steam line with the failed open MSIV, sedimentation is being credited in one single piping volume, between the outboard MSIV and the point where the drain line taps off as it would be difficult to justify deposition in the section upstream of the outboard MSIV. A maximum MSIV leakage of 60 scfh in the line with the failed inboard MSIV is assumed. One of the other lines is assumed to leak at 25 scfh, and the other two lines are assumed not to leak. This modeling is conservative as it minimizes deposition E1-9

credit. The modeling assumes well-mixed control volumes. Only the piping volumes associated with horizontal runs of main steam line piping are included. The amount of fission product aerosol deposition is derived from the methodology in Appendix A to NRC staff report AEB-98-03, "Assessment of the Radiological Consequences for the Perry Pilot Plant Application Using the Revised (NUREG-1465) Source Term" (Reference 7). Particulate deposition in the main condenser is treated using the same approach as that for the steam lines. The deposition of elemental iodine in the MSLs is determined using the NRC staff-accepted RADTRAD model (Reference 7). Because the particulate deposition velocity in the condenser is less than the elemental iodine deposition velocity from NUREG 0800 Section 6.5.2, "Containment Spray As A Fission Product Cleanup System" (Reference 8), TVA used the particulate deposition velocity.

The revised control room and offsite dose analyses continue to utilize AST and the regulatory guidance of Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors" (Reference 9) for BFN Units 1, 2 and 3. The control room and offsite dose results are given in Table 1 while the input parameters are given in Table 2. The computer code RADTRAD was used to calculate the resultant control room and offsite doses. The resulting doses continue to satisfy the radiological dose limits of 10 CFR 50.67 and Regulatory Guide 1.183, which require doses less than five remTEDE for the Control Room (CR),

and 25 rem TEDE for the Exclusion Area Boundary (EAB) and Low Population Zone (LPZ).

Table 1- Control Room and Offsite Dose Results 30-day CR Max-2-hour 30-day LPZ TEDE EAB TEDE (rem) TEDE (1-3 hr) (rem)

(rem)_ (rem) 4.72 5.92 5.4 El-10

Table 2 - Input Data

  1. Description Value 1 Reactor power for core inventory (3952 x 1.02), MWt 4031 No 1.02 factor used for drywell natural desposition calculation (conservative) 2 Number of assemblies in core 764 Reg Guide 3 LOCA Source Term Input 1.183 3

4 Primary Containment Volumes, ft Drywell 159,000 Supression pool air space 119,400 Suppression pool liquid 141,051 5 Reactor Building Volume, ft3 1,311,209 6 Containment leakrate, %/day 2 Drywell to Reactor Building, cfm 2.208 Torus to Reactor Building, cfm 1.658 7 Volume at base of stack (50% of free volume), ft 3 34,560 8 Volumetric Flowrate, Drywell to Main Condenser, cfm 0.363 9 Volumetric Flowrate, Condenser to Environment, cfm 1.107 Volumetric Flowrate, Drywell to Turbine Building 10 (Condenser Bypass), cfm 0.3788 11 Combined MSIV Tested Leak Rate, scfh total 85 12 Per Line MSIV Tested Leak Rate, scfh max per line 60 13 MSIV Leakage Test Pressure - 25 psig 14 CREVS filter efficiency Not Credited 15 Control room intake flow, cfm 6717 16 Control room Volume, ft3 210,000 Hardened wet well vent release (elevated), 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 17 30 days, scfh 10 18 SGTS ground level leakage (base of stack), cfm 20 19 SGTS Stack Flow, cfm 24750 20 SGTS HEPA filter efficiency, particulate, % 90 21 SGTS Charcoal Filter Efficiency, % Not Credited 22 ESF Leakage I Flow, gpm 20 Amount of Iodine that flashes, % 10 Aerosol Elemental 23 Steam Line and Main Condenser Removal Efficiencies Particles Iodine Steam line 99.97 99.70 MC bypass 92.90 25.30 El-11

Table 2 - Input Data (continued)

  1. Description Value 24 Breathing rate, offsite, m3/s 0-8 hours 3.50E-04 8-24 hours 1.80E-04

>24 hours 2.30E-04 25 Breathing rate, control room,m 3/s 3.50E-04 26 Control room occupancy factor 0-24 hrs 1 1-4 days 0.6 4-30 days 0.4 27 Generic Flow Area to HP Turbine, in2 0.0288 28 Min Flow Area of Drainline Pathway, in2 0.0276 29 Reference Atmospheric Pressure, psia 14.4 30 Reference Steam Line Pressure, psia 1050 31 Drywell maximum accident conditions Pressure, psig 48.5 Temperature, F 295.2 32 Volume of Inboard to Outboard MSIV, ft 3 53.7 33 Volume of Outboard MSIV to Drain Line Tap, ft3 173.1 34 Main Condenser Volume, ft 3 122,400 35 Main Condenser Sedimentation Height, ft 27.2 36 Drywell Sprays Not Credited CAD System Release (Activity same as CNMT leakage 37 Case)

Flow rate, cfm 139 CAD operation, days post accident 10, 20, 29 CAD operation duration, hours 24 38 Drywell Natural Deposition Powers 10%

Particulate Model Same as Elemental Particulate 2 3409 39 Surface Area for elemental iodine deposition in DW, m E1-12

Structural Integrity Portions of the main steam piping and components in the Turbine Building at BFN were not originally designed as Seismic Class I. Therefore, seismic verification walkdowns and evaluations of piping/supports were performed to demonstrate the main steam line piping and components that comprise the ALT path were rugged, and would be able to perform the safety function of MSIV leakage control following a design basis event (DBE).

A review of the earthquake experience data on the performance of nuclear power plants and condensers was conducted. Using the experience-based methodology, supplemented by the walkdowns and evaluations, the components in the ALT leakage path can be relied upon to maintain structural integrity. The seismic evaluation results are summarized in the BFN calculation provided in Attachment 9. This calculation documents outliers that required resolution for BFN Units 1, 2, and 3. All outliers documented in the BFN calculation provided in Attachment 9 have been resolved.

These resolutions are documented and verified in References 11, 12, 13, and 14.

In summary, the seismic verification walkdowns and evaluations of piping/supports demonstrated that the main steam line piping and components that comprise the ALT path were rugged, and would be able to perform the safety function of MSIV leakage control following a DBE. Therefore, it has been concluded the components in the ALT leakage path can be relied upon to maintain their structural integrity.

MSIV Leakage Rate Testing The MSIVs will continue to be leakage rate tested in accordance with the Primary Containment Leakage Rate Testing Program described in TS 5.5.12, except that the acceptance criteria for MSIV leakage will be reduced as reflected in this LAR.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The NRC's regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36. The TS requirements in 10 CFR 50.36 include the following categories:

(1) safety limits, limiting safety systems settings, and control settings; (2) LCO; (3) surveillance requirements; (4) design features; and (5) administrative controls.

As stated in 10 CFR 50.59(c)(1 )(i), a licensee is required to submit a license amendment pursuant to 10 CFR 50.90 ifa change to the TSs is required. Furthermore, the requirements of 10 CFR 50.59 necessitate that the NRC approve the TS changes before they are implemented. The TVA submittal meets the requirements of 10 CFR 50.59(c)(1)(i) and 10 CFR 50.90.

The main steam lines, steam drain piping, and the main condenser are used to mitigate the consequences of an accident to limit potential exposures below the doses limits prescribed in 10 CFR 50.67(b)(2)(i) for the exclusion area, 10 CFR 50.67(b)(2)(ii) for the low population zone, and in 10 CFR 50.67(b)(2)(iii) for control room personnel.

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TVA commits to having administrative controls in place to ensure that the power is removed from valve FCV-1-57 to ensure that it remains in the open position.

4.2 Precedent There is not a specific precedent for using the proposed primary ALT Pathway. The previously approved secondary ALT Pathway is the same as the proposed primary ALT Pathway. In Reference 6, the NRC issued an SER on NEDC-31858P, "Safety Evaluation Report of GE Topical Report, NEDC-31858P, Revision 2, BWROG Report for Increasing MSIV Leakage Limits and Elimination of Leakage Control Systems,"

approving NEDC-31858P for use. BFN evaluated the ALT Pathway for the Units 2 and 3 licensing submittal (Reference 2) and the Unit 1 licensing submittal (Reference 4) in accordance with the technical methodology in NEDC-31858P.

4.3 Significant Hazards Consideration The proposed change decreases the leakage rate through each MSIV and the combined leakage rate through all four main steam. Additionally, the proposed change establishes the primary Alternate Leakage Treatment (ALT) Pathway as a flow path through the orifice bypass lines around each of the main steam drain lines, through open valve FCV-1-57, which will have its power removed, through the 0.1875-inch orifice bypass line around valve FCV-1 -58 and the four-inch bypass line around FCV-1 -59 for those events taking credit for the availability of the ALT Pathway to the condenser. This results in an increase in the flow that bypasses the condenser. The primary flow path from the MSIVs to the condenser is passive, and requires no operator actions or valve positions to change to establish the pathway. Furthermore, the proposed change establishes the secondary ALT Pathway through normally open valves FCV-1-168, FCV-1 -169, FCV-1 -170, and FCV-1 -171, and continues through valves FCV-1 -57, FCV-1-58, and FCV-1-59 to the main condenser.

The Tennessee Valley Authority (TVA) has concluded that the proposed change to the Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3 does not involve a significant hazards consideration. TVA's conclusion is based on its evaluation in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.91(a)(1) of the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

1. Does the proposedamendment involve a significantincrease in the probability or consequence of an accidentpreviously evaluated?

Response: No.

The proposed change continues to use the main steam drain lines to direct MSIV leakage to the main condenser, although at a lower rate than is currently allowed.

Therefore, the ALT Pathway takes advantage of the large volume of the steam lines and condenser to provide holdup and plate-out fission products that may leak through the closed MSIVs. Additionally, the main steam lines, main steam drain piping, and the main condenser continue to be used to mitigate the consequences of an accident to limit potential doses below the limits prescribed in 10 CFR 50.67(b)(2)(i) for the exclusion area, 10 CFR 50.67(b)(2)(ii) for the low population zone, and in 10 CFR 50.67(b)(2)(iii) for control room personnel.

El-14

The plant-specific radiological analysis has been re-evaluated to ensure that the effects of the increase in the condenser bypass flow and proposed decrease in MSIV leakage continues to maintain the acceptance criteria in terms of offsite doses and main control room dose. The analysis results comply with the dose limits prescribed in 10 CFR 50.67(b)(2)(i) for the exclusion area, 10 CFR 50.67(b)(2)(ii) for the low population zone, and in 10 CFR 50.67(b)(2)(iii) for control room personnel.

Therefore, the proposed change does not involve a significant increase in the probability or consequence of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accidentfrom any accidentpreviously evaluated?

Response: No.

The proposed change does not involve any physical changes to plant safety related systems, structures, and components (SSCs) or alter the modes of plant operation in a manner that is outside the bounds of the current alternate leakage treatment pathway. Because the safety and design requirements continue to be met and the integrity of the Reactor Coolant System (RCS) pressure boundary is not challenged, no new credible failure mechanisms, malfunctions, or accident initiators are created, and there will be no effect on the accident mitigating systems in a manner that would significantly degrade the plant's response to an accident.

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

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change to Surveillance Requirement 3.6.1.3.10, to decrease the allowable MSIV leakage, and increase the condenser bypass flow due to only crediting the passive ALT Pathway, does not involve a significant reduction in the margin of safety. The allowable leak rate specified for the MSIVs is used to quantify a maximum amount of leakage assumed to bypass containment. The results of the re-analysis supporting these changes were evaluated against the dose limits contained in 10 CFR 50.67(b)(2)(i) for the exclusion area, 10 CFR 50.67(b)(2)(ii) for the low population zone, and 10 CFR 50.67(b)(2)(iii) for control room personnel. Margin relative to the regulatory limits is maintained.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, TVA concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92 (c), and accordingly, a finding of "no significant hazards consideration" is justified.

E1-15

Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Letter from TVA to NRC, "Updated Reply to Notice of Violation; EA-1 1-252; and Follow-up to 10 CFR 50.9, 'Completeness and accuracy of information,' Notification,"

dated August 30, 2013

2. TVA letter to the NRC, "Browns Ferry Nuclear Plant - Units 2 and 3 - Technical Specification (TS) Change 399 - Increasing Main Steam Isolation Valve (MSIV)

Leakage Rate Limits and Exemption from 10 CFR 50, Appendix J," dated September 28, 1999

3. TVA letter to the NRC, "Browns Ferry Nuclear Plant - Units 2 and 3 - Response to Request for Additional Information Regarding Technical Specification (TS) Change 399 -Increased Main Steam Isolation Valve (MSIV) Leakage Rate Limits and Exemption from 10 CFR 50, Appendix J - Revised TS Pages for MSIV Leakage Limits," dated February 4, 2000
4. TVA letter to the NRC, "Browns Ferry Nuclear Plant Unit 1 - Technical Specification (TS) Change 436 - Increased Main Steam Isolation Valve (MSIV) Leakage Rate Limits and Exemption from 10 CFR 50, Appendix J," dated July 9, 2004
5. TVA letter to the NRC, "Browns Ferry Nuclear Plant - Units 1, 2, and 3 -

Supplemental Information Associated with Response to Request for Additional Information (RAI) Related to Technical Specification (TS) Change No. TS-405 -

Alternative Source Term (AST)," dated August 24, 2004

6. NRC letter to General Electric, "Safety Evaluation Report of GE Topical Report, NEDC-31858P, Revision 2, BWROG Report for Increasing MSIV Leakage Limits and Elimination of Leakage Control Systems," September 1993, dated March 3, 1999 E1-16
7. AEB-98-03, "Assessment of the Radiological Consequences for the Perry Pilot Plant Application Using the Revised (NUREG-1465) Source Term. Particulate" dated December 9, 1998
8. NUREG-0800, Section 6.5.2, "Containment Spray As A Fission Product Cleanup System," Revision 4, published March, 2007
9. Regulatory Guide (RG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," published July, 2000
10. NRC letter to TVA, "Browns Ferry Nuclear Plant - NRC Inspection Procedure 95003 Supplemental Inspection Report 05000259/2011011, 05000260/2011011, AND 05000296/2011011 (PART 1), dated November 17, 2011
11. TVA Calculation CDQ2001980069, "Main Steam Seismic Ruggedness Verification -

Unit 2"

12. TVA Calculation CDQ0001980038, "Main Steam Seismic Ruggedness Evaluation"
13. TVA Calculation CDQ0001980039, "Main Steam Seismic Ruggedness Verification -

Unit 3"

14. Calculation TVA/BFN-01-R-003, "MSIV Seismic Ruggedness Verification at BFN Unit 1", EDMS No. W87 070313 001 E1-17

Figure 1 -

BFN Primary "ALT Pathway from Main Steam Lines to Condenser E1-18

Figure 2 I

BFN Secondary "ALT" Pathway from Main Steam Lines to Condenser E1-19

Figure 3 MSIV Seismic Verification Walkdown Boundary E1-20

ATTACHMENT I Proposed Technical Specifications Pages Markups

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.5 Verify the isolation time of each power In accordance operated, automatic PCIV, except for MSIVs, with the Inservice is within limits. Testing Program SR 3.6.1.3.6 Verify the isolation time of each MSIV is > 3 In accordance seconds and < 5 seconds. with the Inservice Testing Program SR 3.6.1.3.7 Verify each automatic PCIV actuates to the 24 months isolation position on an actual or simulated isolation signal.

SR 3.6.1.3.8 Verify a representative sample of reactor 24 months instrumentation line EFCVs actuate to the isolation position on a simulated instrument line break signal.

SR 3.6.1.3.9 Remove and test the explosive squib from 24 months on a each shear isolation valve of the TIP System. STAGGERED TEST BASIS SR 3.6.1.3.10 Verify leakage rate through each MSIV is In accordance scfh and that the combined leakage with the Primary rate for all four main steam lines is < 1-0 scfh Containment when tested at _>25 psig. Leakage Rate Testing Program BFN-UNIT 1 3.6-16 Amendment Nos. 264-264, 277 March 22, 2010

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.5 Verify the isolation time of each power In accordance operated, automatic PCIV, except for MSIVs, with the Inservice is within limits. Testing Program SR 3.6.1.3.6 Verify the isolation time of each MSIV is _>3 In accordance seconds and < 5 seconds. with the Inservice Testing Program SR 3.6.1.3.7 Verify each automatic PCIV actuates to the 24 months isolation position on an actual or simulated isolation signal.

SR 3.6.1.3.8 Verify a representative sample of reactor 24 months instrumentation line EFCVs actuate to the isolation position on a simulated instrument line break signal.

SR 3.6.1.3.9 Remove and test the explosive squib from 24 months on a each shear isolation valve of the TIP System. STAGGERED TEST BASIS SR 3.6.1.3.10 Verify leakage rate through each MSIV is In accordance scfh and that the combined leakage with the Primary rate for all four main steam lines is _ i- scfh Containment when tested at > 25 psig. Leakage Rate Testing Program BFN-UNIT 2 3.6-16 Amendment No. 263, 267, 2, 304 March 22, 2010

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.5 Verify the isolation time of each power In accordance operated, automatic PCIV, except for MSIVs, with the Inservice is within limits. Testing Program SR 3.6.1.3.6 Verify the isolation time of each MSIV is > 3 In accordance seconds and < 5 seconds. with the Inservice Testing Program SR 3.6.1.3.7 Verify each automatic PCIV actuates to the 24 months isolation position on an actual or simulated isolation signal.

SR 3.6.1.3.8 Verify a representative sample of reactor 24 months instrumentation line EFCVs actuate to the isolation position on a simulated instrument line break signal.

SR 3.6.1.3.9 Remove and test the explosive squib from 24 months on a each shear isolation valve of the TIP System. STAGGERED TEST BASIS SR 3.6.1.3.10 Verify leakage rate through each MSIV is In accordance scfh and that the combined leakage with the Primary rate for all four main steam lines is < i scfh Containment when tested at >_25 psig. Leakage Rate Testing Program BFN-UNIT 3 3.6-16 Amendment No. 223, 227, 228, 263 March 22, 2010

ATTACHMENT 2 Proposed Technical Specifications Bases Pages Markups (for information only)

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.9 REQUIREMENTS (continued) The TIP shear isolation valves are actuated by explosive charges. An in place functional test is not possible with this design. The explosive squib is removed and tested to provide assurance that the valves will actuate when required. The replacement charge for the explosive squib shall be from the same manufactured batch as the one fired or from another batch that has been certified by having one of the batch successfully fired. The Frequency of 24 months on a STAGGERED TEST BASIS is considered adequate given the administrative controls on replacement charges and the frequent checks of circuit continuity (SR 3.6.1.3.4).

SR 3.6.1.3.10 The analyses in References 1 and 5 are based on leakage that 60 is less than the specified leakage rate. Leakage through each MSIV must be < . scfh when tested at > Pt (25 psig). The combined leakage rate for all four main steam lines must be 8 _- scfh when tested at __25 psig in accordance with the 60 Primary Containment Leakage Rate Testing Program. If the leakage rate through an individual MSIV exceeds 4-1 scfh, the leakage rate shall be restored below the alarm limit value as specified in the Containment Leakage Rate Testing Program referenced in TS 5.5.12. This ensures that MSIV leakage is properly accounted for in determining the overall primary containment leakage rate. The Frequency is specified in the Primary Containment Leakage Rate Testing Program.

(continued)

BFN-UNIT 1 B 3.6-35 Revision 0, 4,, 62 January 12, 2012

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.9 REQUIREMENTS (continued) The TIP shear isolation valves are actuated by explosive charges. An in place functional test is not possible with this design. The explosive squib is removed and tested to provide assurance that the valves will actuate when required. The replacement charge for the explosive squib shall be from the same manufactured batch as the one fired or from another batch that has been certified by having one of the batch successfully fired. The Frequency of 24 months on a STAGGERED TEST BASIS is considered adequate given the administrative controls on replacement charges and the frequent checks of circuit continuity (SR 3.6.1.3.4).

SR 3.6.1.3.10 The analyses in References 1 and 5 are based on leakage that 60 is less than the specified leakage rate. Leakage through each MSIV must be 4 0 scfh when tested at > Pt (25 psig). The combined leakage rate for all four main steam lines must be T-I'I< scfh when tested at > 25 psig in accordance with the 60 Primary Containment Leakage Rate Testing Program. If the leakage rate through an individual MSIV exceeds 4-0 scfh, the leakage rate shall be restored below the alarm limit value as specified in the Containment Leakage Rate Testing Program referenced in TS 5.5.12. This ensures that MSIV leakage is properly accounted for in determining the overall primary containment leakage rate. The Frequency is specified in the Primary Containment Leakage Rate Testing Program.

(continued)

BFN-UNIT 2 B 3.6-35 Revision 62 Amendment No. 255, 263, 267 January 12, 2012

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.9 REQUIREMENTS (continued) The TIP shear isolation valves are actuated by explosive charges. An in place functional test is not possible with this design. The explosive squib is removed and tested to provide assurance that the valves will actuate when required. The replacement charge for the explosive squib shall be from the same manufactured batch as the one fired or from another batch that has been certified by having one of the batch successfully fired. The Frequency of 24 months on a STAGGERED TEST BASIS is considered adequate given the administrative controls on replacement charges and the frequent checks of circuit continuity (SR 3.6.1.3.4).

SR 3.6.1.3.10 The analyses in References 1 and 5 are based on leakage that 60is less than the specified leakage rate. Leakage through each MSIV must be < 400 scfh when tested at > Pt (25 psig). The combined leakage rate for all four main steam lines must be 7 scfh when tested at > 25 psig in accordance with the 60 Primary Containment Leakage Rate Testing Program. Ifthe leakage rate through an individual MSIV exceeds-i- scfh, the leakage rate shall be restored below the alarm limit value as specified in the Containment Leakage Rate Testing Program referenced in TS 5.5.12. This ensures that MSIV leakage is properly accounted for in determining the overall primary containment leakage rate. The Frequency is specified in the Primary Containment Leakage Rate Testing Program.

(continued)

BFN-UNIT 3 B 3.6-35 Revision 62 Amendment No. 24-2, 2-1-5, 22-3, 227 January 12, 2012

ATTACHMENT 3 Proposed Retyped Technical Specifications Pages

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.5 Verify the isolation time of each power In accordance operated, automatic PCIV, except for MSIVs, with the Inservice is within limits. Testing Program SR 3.6.1.3.6 Verify the isolation time of each MSIV is _Ž 3 In accordance seconds and < 5 seconds. with the Inservice Testing Program SR 3.6.1.3.7 Verify each automatic PCIV actuates to the 24 months isolation position on an actual or simulated isolation signal.

SR 3.6.1.3.8 Verify a representative sample of reactor 24 months instrumentation line EFCVs actuate to the isolation position on a simulated instrument line break signal.

SR 3.6.1.3.9 Remove and test the explosive squib from 24 months on a each shear isolation valve of the TIP System. STAGGERED TEST BASIS SR 3.6.1.3.10 Verify leakage rate through each MSIV is In accordance

< 60 scfh and that the combined leakage rate with the Primary for all four main steam lines is < 85 scfh when Containment tested at > 25 psig. Leakage Rate Testing Program BFN-UNIT 1 3.6-16 Amendment Nos. 2-64, 2-64, 2-7-7,

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.5 Verify the isolation time of each power In accordance operated, automatic PCIV, except for MSIVs, with the Inservice is within limits. Testing Program SR 3.6.1.3.6 Verify the isolation time of each MSIV is >_3 In accordance seconds and < 5 seconds. with the Inservice Testing Program SR 3.6.1.3.7 Verify each automatic PCIV actuates to the 24 months isolation position on an actual or simulated isolation signal.

SR 3.6.1.3.8 Verify a representative sample of reactor 24 months instrumentation line EFCVs actuate to the isolation position on a simulated instrument line break signal.

SR 3.6.1.3.9 Remove and test the explosive squib from 24 months on a each shear isolation valve of the TIP System. STAGGERED TEST BASIS SR 3.6.1.3.10 Verify leakage rate through each MSIV is In accordance

< 60 scfh and that the combined leakage rate with the Primary for all four main steam lines is < 85 scfh when Containment tested at _Ž 25 psig. Leakage Rate Testing Program BFN-UNIT 2 3.6-16 Amendment No. 26,, 26-7, 2-6, ,94,

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.5 Verify the isolation time of each power In accordance operated, automatic PCIV, except for MSIVs, with the Inservice is within limits. Testing Program SR 3.6.1.3.6 Verify the isolation time of each MSIV is Ž_3 In accordance seconds and < 5 seconds. with the Inservice Testing Program SR 3.6.1.3.7 Verify each automatic PCIV actuates to the 24 months isolation position on an actual or simulated isolation signal.

SR 3.6.1.3.8 Verify a representative sample of reactor 24 months instrumentation line EFCVs actuate to the isolation position on a simulated instrument line break signal.

SR 3.6.1.3.9 Remove and test the explosive squib from 24 months on a each shear isolation valve of the TIP System. STAGGERED TEST BASIS SR 3.6.1.3.10 Verify leakage rate through each MSIV is In accordance

< 60 scfh and that the combined leakage rate with the Primary for all four main steam lines is _<85 scfh when Containment tested at > 25 psig. Leakage Rate Testing Program BFN-UNIT 3 3.6-16 Amendment No. 22-3,-22-7, 228, 2-63,

ATTACHMENT 4 Proposed Retyped Technical Specifications Bases Pages (for information only)

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.9 REQUIREMENTS (continued) The TIP shear isolation valves are actuated by explosive charges. An in place functional test is not possible with this design. The explosive squib is removed and tested to provide assurance that the valves will actuate when required. The replacement charge for the explosive squib shall be from the same manufactured batch as the one fired or from another batch that has been certified by having one of the batch successfully fired. The Frequency of 24 months on a STAGGERED TEST BASIS is considered adequate given the administrative controls on replacement charges and the frequent checks of circuit continuity (SR 3.6.1.3.4).

SR 3.6.1.3.10 The analyses in References 1 and 5 are based on leakage that is less than the specified leakage rate. Leakage through each MSIV must be < 60 scfh when tested at > Pt (25 psig). The combined leakage rate for all four main steam lines must be

<_85 scfh when tested at _>25 psig in accordance with the Primary Containment Leakage Rate Testing Program. Ifthe leakage rate through an individual MSIV exceeds 60 scfh, the leakage rate shall be restored below the alarm limit value as specified in the Containment Leakage Rate Testing Program referenced in TS 5.5.12. This ensures that MSIV leakage is properly accounted for in determining the overall primary containment leakage rate. The Frequency is specified in the Primary Containment Leakage Rate Testing Program.

(continued)

BFN-UNIT 1 B 3.6-35 Revision 0, 43, 62,

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.9 REQUIREMENTS (continued) The TIP shear isolation valves are actuated by explosive charges. An in place functional test is not possible with this design. The explosive squib is removed and tested to provide assurance that the valves will actuate when required. The replacement charge for the explosive squib shall be from the same manufactured batch as the one fired or from another batch that has been certified by having one of the batch successfully fired. The Frequency of 24 months on a STAGGERED TEST BASIS is considered adequate given the administrative controls on replacement charges and the frequent checks of circuit continuity (SR 3.6.1.3.4).

SR 3.6.1.3.10 The analyses in References 1 and 5 are based on leakage that is less than the specified leakage rate. Leakage through each MSIV must be < 60 scfh when tested at _>Pt (25 psig). The combined leakage rate for all four main steam lines must be

< 85 scfh when tested at > 25 psig in accordance with the Primary Containment Leakage Rate Testing Program. If the leakage rate through an individual MSIV exceeds 60 scfh, the leakage rate shall be restored below the alarm limit value as specified in the Containment Leakage Rate Testing Program referenced in TS 5.5.12. This ensures that MSIV leakage is properly accounted for in determining the overall primary containment leakage rate. The Frequency is specified in the Primary Containment Leakage Rate Testing Program.

(continued)

BFN-UNIT 2 B 3.6-35 Revision 62, Amendment No. 255, 2-6,, 2 PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.9 REQUIREMENTS (continued) The TIP shear isolation valves are actuated by explosive charges. An in place functional test is not possible with this design. The explosive squib is removed and tested to provide assurance that the valves will actuate when required. The replacement charge for the explosive squib shall be from the same manufactured batch as the one fired or from another batch that has been certified by having one of the batch successfully fired. The Frequency of 24 months on a STAGGERED TEST BASIS is considered adequate given the administrative controls on replacement charges and the frequent checks of circuit continuity (SR 3.6.1.3.4).

SR 3.6.1.3.10 The analyses in References 1 and 5 are based on leakage that is less than the specified leakage rate. Leakage through each MSIV must be < 60 scfh when tested at > Pt (25 psig). The combined leakage rate for all four main steam lines must be

< 85 scfh when tested at > 25 psig in accordance with the Primary Containment Leakage Rate Testing Program. If the leakage rate through an individual MSIV exceeds 60 scfh, the leakage rate shall be restored below the alarm limit value as specified in the Containment Leakage Rate Testing Program referenced in TS 5.5.12. This ensures that MSIV leakage is properly accounted for in determining the overall primary containment leakage rate. The Frequency is specified in the Primary Containment Leakage Rate Testing Program.

(continued)

BFN-UNIT 3 B 3.6-35 Revision 62, Amendment No. 24-2, 2-1-5, 223, 227

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