Text

Application to Revise Technical Specifications to Adopt TSTF-545, Rev. 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, to Request Alternative to the ASME Code, and To..
	ML17018A149
Person / Time
Site:	Browns Ferry
Issue date:	01/17/2017
From:	James Shea; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
	BFN-TS-495, CNL-16-155
	Download: ML17018A149 (151)
	v • d • e

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-16-155 January 17, 2017 10 CFR 50.90 10 CFR 50.55a 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, 50-296, and 72-052

SUBJECT:

Application to Revise Technical Specifications to Adopt TSTF-545, Rev. 3, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," to Request an Alternative to the ASME Code, and to Implement Administrative TSTF-299, Rev. 0, Administrative Controls Program 5.5.2.b Test Interval and Exception (BFN-TS-495)

REFERENCES:

1. TSTF-545, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," Revision 3, dated October 21, 2015 (ML15294A555)

2. TSTF-299, Administrative Controls Program 5.5.2.b Test Interval and Exception, NRC Received Date: November 12, 1998, (ML040620202)

3. Letter from W. D. Beckner (NRC) to A. R. Pietrangelo (Nuclear Energy Institute),

"TSTF Status Report - October 2000," dated October 31, 2000, (ML003765449)

Pursuant to 10 CFR 50.90, Tennessee Valley Authority (TVA) is submitting a request for an amendment to the Technical Specifications (TS) for Browns Ferry Nuclear Plant, Units 1, 2, and 3. The proposed change revises the Technical Specifications (TS) to eliminate the "Inservice Testing Program, contained in TS Section 5.5.6 and replace the program with a new defined term, "Inservice Testing Program," in the TS Definitions section. This request is consistent with TSTF-545, Revision 3, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing. Additionally, TVA is requesting implementation of Administrative TSTF-299, Rev. 0, Administrative Controls Program 5.5.2.b Test Interval and Exception, which clarifies the intent of refueling cycle intervals with respect to the system leak test requirements (i.e., 24 month intervals) and adds the following sentence, The provisions of SR 3.0.2 are applicable.

U.S. Nuclear Regulatory Commission CNL-16-155 Page 2 January 17, 2017 Pursuant to 10 CFR 50.55a(z) , the application also proposes an alternative to the testing frequencies in the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code, by adoption of approved Code Case OMN-20 , "lnservice Test Frequency," for the current 10 year lnservice Testing (IST) interval. provides a description and assessment of the proposed TS changes . Enclosure 2 provides the existing TS pages marked up to show the proposed changes . Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides TS Bases pages marked up to show the associated TS Bases changes and is provided for information only. Enclosure 5 provides revised (clean) TS Bases pages and is provided for information only. Enclosure 6 provides the request for an alternative to the ASME Code.

Approval of the proposed amendment and relief request is requested by January 16, 2018 .

Once approved , the amendment shall be implemented within 60 days.

In accordance with 10 CFR 50.91 , a copy of this application , with enclosures, is being provided to the Alabama State Department of Public Health .

There are no new regulatory commitments associated with this submittal. If you should have any questions regarding this submittal , please contact Ed Schrull at (423) 751-3850.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 17th day of January 2017.

Jo eph W . Shea Vice President - Nuclear Licensing Enclosures cc: See Page 3

U.S. Nuclear Regulatory Commission CNL-16-155 Page 3 January 17, 2017 Enclosures

1. Description and Assessment of Technical Specifications Changes

2. Proposed Technical Specification Changes (Mark-Up)

3. Revised Technical Specification Pages

4. Proposed Technical Specification Bases Changes (Mark-Up) - Information Only

5. Revised Technical Specification Bases Changes - Information Only

6. Description and Assessment of the Proposed Alternative to the ASME Code cc:(Enclosures)

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant State Health Officer, Alabama State Department of Public Health NRC Branch Chief - Region II

ENCLOSURE 1 DESCRIPTION AND ASSESSMENT OF TECHNICAL SPECIFICATIONS CHANGES Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3

1.0 DESCRIPTION

The proposed change eliminates the "Inservice Testing Program" contained in Technical Specification (TS) Section 5.5.6 to remove requirements duplicated in American Society of Mechanical Engineers (ASME) Code for Operations and Maintenance of Nuclear Power Plants (OM Code), Case OMN-20, "Inservice Test Frequency. TS Section 5.5.6 will provide a reference to a new defined term, "Inservice Testing Program," which will be added to TS Section 1.1, "Definitions. The proposed change to the TS is consistent with Technical Specification Task Force (TSTF) TSTF-545, Rev. 3, "TS Inservice Testing Program Removal &

Clarify SR Usage Rule Application to Section 5.5 Testing."

The proposed change also revises TS 5.5.2, "Primary Coolant Sources Outside Containment,"

to clarify the intent of refueling cycle intervals (i.e., 24 month intervals) with respect to system leak test requirements and to add a statement that the provisions of Surveillance Requirement (SR) 3.0.2 are applicable. The changes are consistent with TSTF-299, Rev. 0, "Administrative Controls Program 5.5.2.b Test Interval and Exception.

2.0 ASSESSMENT 2.1 TSTF-545 - Applicability of Published Safety Evaluation Tennessee Valley Authority (TVA) has reviewed the model safety evaluation provided in the Federal Register Notice of Availability dated March 28, 2016, (81 FR 17208) to the TSTF in a letter dated December 11, 2015 (ML15314A365). This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-545. TVA concluded that the justifications presented in TSTF-545, and the model safety evaluation prepared by the NRC staff, are applicable to Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, and justify this amendment for the incorporation of the changes to the BFN TS.

BFN Unit 1 was issued a construction permit on May 10, 1967, and the provisions of 10 CFR 50.55a(f)(1) are applicable.

BFN Unit 2 was issued a construction permit on May 10, 1967, and the provisions of 10 CFR 50.55a(f)(1) are applicable.

BFN Unit 3 was issued a construction permit on July 31, 1968, and the provisions of 10 CFR 50.55a(f)(1) are applicable.

CNL-16-155 Page E1-1 of 7

2.2 TSTF-545 - Variations TVA is proposing variations listed below from the TS changes described in TSTF-545 or the applicable parts of the NRC staffs model safety evaluation dated December 11, 2015. These variations are administrative and do not affect the applicability of TSTF-545 or the NRC staff's model safety evaluation to the proposed license amendment.

In some cases, the BFN Units 1, 2, and 3 TS utilize different numbering than the Standard Technical Specifications on which TSTF-545 was based. In other cases, TSTF-545 changes were not applicable because the associated specification is not contained in the BFN Units 1, 2, and 3 TS.

TSTF-545 deletes TS 5.5.7 (BFN section 5.5.6), Inservice Testing Program, and renumbers all subsequent TS programs. Renumbering TS programs impacts several TS Bases references and a large number of station procedures. TVA proposes to retain the BFN TS 5.5.6 and replace the text with: Note: See Section 1.1 for the definition of INSERVICE TESTING PROGRAM. TVA also proposes retaining the subsequent TS program numbering. By retaining the current program numbering and including the note, excessive administrative burden is avoided.

BFN Units 1, 2, and 3 TS SR 3.6.1.6.2, (re: TS 3.6.1.6 Suppression Chamber-to-Drywell Vacuum Breakers) specifies a FREQUENCY of In accordance with the Inservice Testing Program. Although this section is not explicitly listed in TSTF-545, TVA proposes substituting Inservice Testing Program with INSERVICE TESTING PROGRAM to be consistent with the TSTF-545 changes.

The proposed differences are administrative and do not affect the applicability of TSTF-545 to the BFN Units 1, 2, and 3 TS.

TSTF-545 Variations (TS numbers listed are from TSTF-545 unless otherwise noted):

Implemented - corresponding TSs differs in numerical designator:

TSTF-545 BFN TS SR 3.5.1.7 SR 3.5.1.6 SR 3.5.2.5 SR 3.5.2.4 SR 3.6.1.3.6 SR 3.6.1.3.5 SR 3.6.1.3.8 SR 3.6.1.3.6 5.5.7 5.5.6*

Note: Rather than deleting TS section 5.5.6 and renumbering subsequent sections, the text of TS 5.5.6 was replaced by Note: See Section 1.1 for the definition of INSERVICE TESTING PROGRAM.

CNL-16-155 Page E1-2 of 7

Not implemented - burdensome section number changes as discussed above:

LCO 3.0.6 TS 5.5.8 - 5.5.13 TS 5.5.15 Not Implemented - not applicable to BFN:

SR 3.1.7.7 SR 3.4.5.1 SR 3.6.2.4.2 SR 3.6.4.2.2 TS 5.5.14, 16, 17 Addition - Consistent with TSTF-545: BFN SR 3.6.1.6.2 FREQUENCY is being changed from Inservice Testing Program to INSERVICE TESTING PROGRAM.

TVA performed a search of the BFN Units 1, 2, and 3 TSs Bases for the key phrase "Inservice Testing Program. Consistent with TSTF-545, all instances of "Inservice Testing Program" were replaced by INSERVICE TESTING PROGRAM. (Note: the TS Bases markups included in are submitted for information only).

2.3 TSTF-299 TVA has reviewed TSTF-299, Rev. 0, Administrative Controls Program 5.5.2.b Test Interval and Exception, Rev. 0, with regard to BFN Units 1, 2, and 3 and concluded that implementation would continue to provide adequate safety because the change is administrative in nature. In Reference 1, the NRC acknowledged their approval of the TSTF-299, Rev. 0, which is applicable to NUREG 1433. Reference 2 provides an example of NRC approval of TSTF-299 implementation. The revised wording is a voluntary administrative change to the TS that does not alter the design basis of the plant.

The revised TS 5.5.2.b will require system leak testing at least once per 24 months. However, a refueling cycle interval may be longer than 24 months in order to achieve the required fuel burn-up, because of shutdowns and power reductions. Incorporating the allowance to apply a 25 percent frequency extension, as provided in SR 3.0.2, to the system leak test requirements allows flexibility in scheduling that is inherent in the current requirement of at refueling cycle intervals or less. The applicability of SR 3.0.2 must be explicitly stated in TS 5.5.2 because SR 3.0.2 only applies to SRs in TS Sections 3.0 through 3.10, unless specifically stated.

The fixed testing frequency of at least once every 24 months is more precise than the current frequency of at refueling cycle intervals or less and is consistent with similar requirements in the BFN TS and the Standard Technical Specifications (STS). BFN Units 1, 2, and 3 are currently on a 24-month fuel cycle. Therefore, adopting this more precise terminology is a clarification of the test frequency. The proposed TS change implementing TSTF-299 is administrative in nature.

Extending the test frequency by 25 percent is consistent with the test extension permitted in the STS. The 25 percent test frequency extension provides flexibility to perform the testing during refueling outages where the fuel cycle was extended due to a lengthy forced shutdown or operation at reduced power.

System leak tests required by TS 5.5.2, Primary Coolant Sources Outside Containment, have passed this surveillance during numerous test cycles at the current 24-month interval. These components are routinely inspected during normal operations and/or testing, such that any degradation would be apparent and corrective actions implemented.

CNL-16-155 Page E1-3 of 7

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis TVA requests adoption of the Technical Specification (TS) changes described in TSTF-545, Rev. 3, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," and TSTF-299, Rev. 0, Administrative Controls Program 5.5.2.b Test Interval and Exception, which are approved changes to the Improved Standard Technical Specifications (ISTS), into the Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3 TS.

The proposed TSTF-545 change revises the TS Chapter 5, "Administrative Controls,"

Section 5.5, "Programs and Manuals," to delete the contents of the "Inservice Testing (IST)

Program. Requirements in the IST Program are removed, as they are duplicative of requirements in the American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code, as clarified by Code Case OMN-20, "Inservice Test Frequency.

Other requirements in Section 5.5 are eliminated because the Nuclear Regulatory Commission (NRC) has determined their appearance in the TS is contrary to regulations. A new defined term, "Inservice Testing Program," is added, which references the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, paragraph 50.55a(f).

The proposed TSTF-299 administrative change revises TS 5.5.2, "Primary Coolant Sources Outside Containment" to clarify the intent of refueling cycle intervals (i.e., 24 month intervals) with respect to system leak test requirements and to add a statement that the provisions of Surveillance Requirement (SR) 3.0.2 are applicable.

TVA has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No TSTF 545, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," Rev. 3:

The proposed change revises TS Chapter 5, "Administrative Controls," Section 5.5, "Programs and Manuals," by eliminating the "Inservice Testing Program" specification.

Most requirements in the Inservice Testing Program are removed, as they are duplicative of requirements in the ASME OM Code, as clarified by Code Case OMN-20, "Inservice Test Frequency. The remaining requirements in the Section 5.5 IST Program are eliminated because the NRC has determined their inclusion in the TS is contrary to regulations. A new defined term, "Inservice Testing Program," is added to the TS, which references the requirements of 10 CFR 50.55a(f).

Performance of inservice testing is not an initiator to any accident previously evaluated.

As a result, the probability of occurrence of an accident is not significantly affected by the proposed change. Inservice test frequencies under Code Case OMN-20 are equivalent to the current testing period allowed by the TS with the exception that testing frequencies greater than 2 years may be extended by up to 6 months to facilitate test CNL-16-155 Page E1-4 of 7

scheduling and consideration of plant operating conditions that may not be suitable for performance of the required testing. The testing frequency extension will not affect the ability of the components to mitigate any accident previously evaluated as the components are required to be operable during the testing period extension.

Performance of inservice tests utilizing the allowances in OMN-20 will not significantly affect the reliability of the tested components. As a result, the availability of the affected components, as well as their ability to mitigate the consequences of accidents previously evaluated, is not affected.

TSTF-299, Administrative Controls Program 5.5.2.b Test Interval and Exception, Rev. 0:

The proposed change affects only the interval at which system leak tests are performed, not the effectiveness of the system leak test requirements. Revising the system leak test requirements from "at refueling cycle intervals or less" to "at least once per 24 months" is considered to be an administrative change because BFN Units 1, 2, and 3 operate on 24-month fuel cycles. Incorporation of the allowance to extend the 24-month interval by 25%, as allowed by Surveillance Requirement (SR) 3.0.2, does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency.

Test intervals are not considered as initiators of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased by the proposed amendment. Technical Specification (TS) 5.5.2 continues to require the performance of periodic system leak tests. Therefore, accident analysis assumptions will still be verified. As a result, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?

Response: No TSTF 545, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," Rev. 3:

The proposed change does not alter the design or configuration of the plant. The proposed change does not involve a physical alteration of the plant; no new or different kind of equipment will be installed. The proposed change does not alter the types of inservice testing performed. In most cases, the frequency of inservice testing is unchanged. However, the frequency of testing would not result in a new or different kind of accident from any previously evaluated since the testing methods are not altered.

CNL-16-155 Page E1-5 of 7

TSTF-299, Administrative Controls Program 5.5.2.b Test Interval and Exception, Rev. 0:

The proposed change affects only the interval at which system leak tests are performed; they do not alter the design or physical configuration of the plant. No changes are being made to BFN Units 1, 2, or 3 that would introduce any new accident causal mechanisms.

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

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

Response: No TSTF 545, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," Rev. 3:

The proposed change eliminates some requirements from the TS in lieu of requirements in the ASME Code, as modified by use of Code Case OMN-20. Compliance with the ASME Code is required by 10 CFR 50.55a. The proposed change also allows inservice tests with frequencies greater than 2 years to be extended by 6 months to facilitate test scheduling and consideration of plant operating conditions that may not be suitable for performance of the required testing. The testing frequency extension will not affect the ability of the components to respond to an accident as the components are required to be operable during the testing period extension. The proposed change will eliminate the existing TS SR 3.0.3 allowance to defer performance of missed inservice tests up to the duration of the specified testing frequency, and instead will require an assessment of the missed test on equipment operability. This assessment will consider the effect on a margin of safety (equipment operability). Should the component be inoperable, the Technical Specifications provide actions to ensure that the margin of safety is protected.

The proposed change also eliminates a statement that nothing in the ASME Code should be construed to supersede the requirements of any TS. The NRC has determined that statement to be incorrect. However, elimination of the statement will have no effect on plant operation or safety.

TSTF-299, Administrative Controls Program 5.5.2.b Test Interval and Exception, Rev. 0:

The proposed change does not change the design or function of plant equipment. The proposed change does not significantly reduce the level of assurance that any plant equipment will be available to perform its function. The proposed change provides operating flexibility without significantly affecting plant operation.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, TVA concludes that the proposed change presents no 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.

CNL-16-155 Page E1-6 of 7

4.0 ENVIRONMENTAL EVALUATION The proposed change 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, or would change an inspection or surveillance requirement. However, the proposed change 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 change 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 change.

5.0 REFERENCES

1. Letter from W. D. Beckner (NRC) to A. R. Pietrangelo (Nuclear Energy Institute),

"TSTF Status Report - October 2000," dated October 31, 2000 (ML003765449)

2. Letter from M. J. David (NRC) to C. G. Pardee (Exelon Generation Company, LLC),

Braidwood Station, Units 1 And 2, and Byron Station, Unit Nos. 1 and 2 - Issuance of Amendments Re: Revision to Technical Specifications For Primary Coolant Sources Outside Containment (TAC NOS. MD6224, MD6225, MD6226, AND MD6227), dated June 18, 2008 (ML081510165)

CNL-16-155 Page E1-7 of 7

ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Attachment 1 - Unit 1 Attachment 2 - Unit 2 Attachment 3 - Unit 3

ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Attachment 1 - Unit 1

Definitions 1.1 1.1 Definitions (continued)

CORE OPERATING LIMITS The COLR is the unit specific document that provides REPORT (COLR) cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table III of TID-14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites."

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee

PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

(continued)

BFN-UNIT 1 1.1-3 Amendment No. 234

S/RVs 3.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 Verify the safety function lift settings of the In accordance required 12 S/RVs are within +/- 3% of the with the Inservice setpoint as follows: Testing Program INSERVICE TESTING Number of Setpoint PROGRAM S/RVs (psig) 4 1135 4 1145 5 1155 Following testing, lift settings shall be within

+/- 1%.

SR 3.4.3.2 ---------------------------NOTE------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify each required S/RV opens when 24 months manually actuated.

BFN-UNIT 1 3.4-8 Amendment No. 234, 263, 269 March 06, 2007

ECCS - Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.5 -------------------------NOTES------------------------

1. Only required to be performed when in MODE 4 > 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

2. Not required to be performed if performed within the previous 31 days.

Verify each recirculation pump discharge Once prior to valve cycles through one complete cycle of entering MODE 2 full travel. from MODE 3 or 4

SR 3.5.1.6 Verify the following ECCS pumps develop the In accordance specified flow rate against a system head with the Inservice corresponding to the specified pressure. Testing Program INSERVICE SYSTEM HEAD CORRESPONDING TESTING TO A VESSEL TO PROGRAM TORUS NO. OF DIFFERENTIAL SYSTEM FLOW RATE PUMPS PRESSURE OF Core Spray t 6250 gpm 2 t 105 psid INDICATED NO. OF SYSTEM SYSTEM FLOW RATE PUMPS PRESSURE LPCI t 12,000 gpm 2 t 250 psig LPCI t 9,000 gpm 1 t 125 psig (continued)

BFN-UNIT 1 3.5-5 Amendment No. 234

ECCS - Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.4 Verify each required ECCS pump develops In accordance the specified flow rate against a system head with the Inservice corresponding to the specified pressure. Testing Program SYSTEM HEAD INSERVICE CORRESPONDING TESTING TO A VESSEL TO PROGRAM TORUS NO. OF DIFFERENTIAL SYSTEM FLOW RATE PUMPS PRESSURE OF CS t 6250 gpm 2 t 105 psid INDICATED NO. OF SYSTEM SYSTEM FLOW RATE PUMPS PRESSURE LPCI t 9,000 gpm 1 t 125 psig SR 3.5.2.5 --------------------------NOTE-------------------------

Vessel injection/spray may be excluded.

Verify each required ECCS injection/spray 24 months subsystem actuates on an actual or simulated automatic initiation signal.

BFN-UNIT 1 3.5-11 Amendment No. 234, 263 September 28, 2006

PCIVs 3.6.1.3 INSERVICE TESTING SURVEILLANCE REQUIREMENTS (continued) PROGRAM 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 t 3 In accordance seconds and d 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 INSERVICE isolation signal.

TESTING PROGRAM 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 d 100 scfh and that the combined leakage with the Primary rate for all four main steam lines is d 150 scfh Containment when tested at t 25 psig. Leakage Rate Testing Program BFN-UNIT 1 3.6-16 Amendment Nos. 264 261, 277 March 22, 2010

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.6.1 -------------------------NOTES------------------------

1. Not required to be met for vacuum breakers that are open during Surveillances.

2. One drywell suppression chamber vacuum breaker may be nonfully closed INSERVICE so long as it is determined to be not more TESTING than 3q open as indicated by the position PROGRAM lights.

Verify each vacuum breaker is closed. 14 days SR 3.6.1.6.2 Perform a functional test of each required In accordance vacuum breaker. with the Inservice Testing Program SR 3.6.1.6.3 Verify the differential pressure required to 24 months open each vacuum breaker is d 0.5 psid.

BFN-UNIT 1 3.6-23 Amendment No. 234, 263 September 28, 2006

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling 31 days subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.

SR 3.6.2.3.2 Verify each RHR pump develops a flow rate In accordance t 9000 gpm through the associated heat with the Inservice exchanger while operating in the suppression Testing Program pool cooling mode.

INSERVICE TESTING PROGRAM BFN-UNIT 1 3.6-33 Amendment No. 234

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.1 Offsite Dose Calculation Manual (ODCM) (continued)

c. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

5.5.2 Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The systems include the Core Spray, High Pressure Coolant Injection, Residual Heat Removal, and Reactor Core Isolation Cooling. The program shall include the following preventive maintenance:

a. Periodic visual inspection requirements; and

b. System leak test requirements for each system, to the extent permitted by system design and radiological conditions, at refueling cycle intervals or less.

The provisions of SR 3.0.2 are applicable. least once per 24 months.

(continued)

BFN-UNIT 1 5.0-9 Amendment No. 234

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.4 Radioactive Effluent Controls Program (continued)

h. Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I;

i. Limitations on the annual and quarterly doses to a member of the public from iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half lives > 8 days in gaseous effluents released from each unit to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I; and

j. Limitations on the annual dose or dose commitment to any member of the public beyond the site boundary due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190.

k. The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Radioactive Effluent Controls Program surveillance frequency.

5.5.5 Component Cyclic or Transient Limit This program provides controls to track the FSAR Section 4.2.5, cyclic and transient occurrences to ensure that components are maintained within the design limits.

5.5.6 Inservice Testing Program This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 components. The program shall include the following:

a. Testing frequencies applicable to the ASME Code for Operations and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda as follows:

Note: See Section 1.1 for the definition of INSERVICE TESTING PROGRAM (continued)

BFN-UNIT 1 5.0-12 Amendment No. 234, 239, 283 August 30, 2013

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.6 Inservice Testing Program (continued) 'HOHWHG ASME OM Code and applicable Addenda Required Frequencies for terminology for inservice performing inservice testing testing activities activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every At least once per 184 days 6 months Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days

b. The provisions of SR 3.0.2 are applicable to the above required Frequencies and to other normal and accelerated Frequencies specified as 2 years or less in the Inservice Test Program for performing Inservice testing activities;

c. The provisions of SR 3.0.3 are applicable to inservice testing activities; and

d. Nothing in the ASME OM Code shall be construed to supersede the requirements of any TS.

(continued)

BFN-UNIT 1 5.0-13 Amendment No. 234, 283 August 30, 2013

ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Attachment 2 - Unit 2

Definitions 1.1 1.1 Definitions (continued)

CORE OPERATING LIMITS The COLR is the unit specific document that provides REPORT (COLR) cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table III of TID-14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites."

,16(59,&(7(67,1* 7KH,16(59,&(7(67,1*352*5$0LVWKHOLFHQVHH

352*5$0 SURJUDPWKDWIXOILOOVWKHUHTXLUHPHQWVRI&)5D I

(continued)

BFN-UNIT 2 1.1-3 Amendment No. 253

S/RVs 3.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 Verify the safety function lift settings of the In accordance required 12 S/RVs are within +/- 3% of the with the Inservice setpoint as follows: Testing Program

,16(59,&(7(67,1*

Number of Setpoint 352*5$0 S/RVs (psig) 4 1135 4 1145 5 1155 Following testing, lift settings shall be within

+/- 1%.

SR 3.4.3.2 ---------------------------NOTE------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify each required S/RV opens when 24 months manually actuated.

BFN-UNIT 2 3.4-8 Amendment No. 255 November 30, 1998

ECCS - Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.5 -------------------------NOTES------------------------

1. Only required to be performed when in MODE 4 > 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

2. Not required to be performed if performed within the previous 31 days.

Verify each recirculation pump discharge Once prior to valve cycles through one complete cycle of entering MODE 2 full travel. from MODE 3 or 4

SR 3.5.1.6 Verify the following ECCS pumps develop the In accordance specified flow rate against a system head with the Inservice corresponding to the specified pressure. Testing Program SYSTEM HEAD INSERVICE CORRESPONDING TESTING TO A VESSEL TO TORUS PROGRAM NO. OF DIFFERENTIAL SYSTEM FLOW RATE PUMPS PRESSURE OF Core Spray t 6250 gpm 2 t 105 psid INDICATED NO. OF SYSTEM SYSTEM FLOW RATE PUMPS PRESSURE LPCI t 12,000 gpm 2 t 250 psig LPCI t 9,000 gpm 1 t 125 psig (continued)

BFN-UNIT 2 3.5-5 Amendment No. 253

ECCS - Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.4 Verify each required ECCS pump develops In accordance the specified flow rate against a system head with the Inservice corresponding to the specified pressure. Testing Program SYSTEM HEAD INSERVICE CORRESPONDING TESTING TO A VESSEL TO PROGRAM TORUS NO. OF DIFFERENTIAL SYSTEM FLOW RATE PUMPS PRESSURE OF CS t 6250 gpm 2 t 105 psid INDICATED NO. OF SYSTEM SYSTEM FLOW RATE PUMPS PRESSURE LPCI t 9,000 gpm 1 t 125 psig SR 3.5.2.5 --------------------------NOTE-------------------------

Vessel injection/spray may be excluded.

Verify each required ECCS injection/spray 24 months subsystem actuates on an actual or simulated automatic initiation signal.

BFN-UNIT 2 3.5-11 Amendment No. 255 November 30, 1998

PCIVs 3.6.1.3 INSERVICE TESTING SURVEILLANCE REQUIREMENTS (continued) PROGRAM 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 t 3 In accordance seconds and d 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 INSERVICE isolation signal. TESTING PROGRAM 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 d 100 scfh and that the combined leakage with the Primary rate for all four main steam lines is d 150 scfh Containment when tested at t 25 psig. Leakage Rate Testing Program BFN-UNIT 2 3.6-16 Amendment No. 263, 267, 268, 304 March 22, 2010

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.6.1 -------------------------NOTES------------------------

1. Not required to be met for vacuum breakers that are open during Surveillances.

INSERVICE

2. One drywell suppression chamber TESTING vacuum breaker may be nonfully closed PROGRAM so long as it is determined to be not more than 3q open as indicated by the position lights.

Verify each vacuum breaker is closed. 14 days SR 3.6.1.6.2 Perform a functional test of each required In accordance vacuum breaker. with the Inservice Testing Program SR 3.6.1.6.3 Verify the differential pressure required to 24 months open each vacuum breaker is d 0.5 psid.

BFN-UNIT 2 3.6-23 Amendment No. 255 November 30, 1998

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling 31 days subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.

SR 3.6.2.3.2 Verify each RHR pump develops a flow rate In accordance t 9000 gpm through the associated heat with the Inservice exchanger while operating in the suppression Testing Program pool cooling mode.

INSERVICE TESTING PROGRAM BFN-UNIT 2 3.6-33 Amendment No. 253

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.1 Offsite Dose Calculation Manual (ODCM) (continued)

c. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

5.5.2 Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The systems include the Core Spray, High Pressure Coolant Injection, Residual Heat Removal, and Reactor Core Isolation Cooling. The program shall include the following preventive maintenance:

a. Periodic visual inspection requirements; and

b. System leak test requirements for each system, to the extent permitted by system design and radiological conditions, at refueling cycle intervals or less.

The provisions of SR 3.0.2 are applicable. least once per 24 months.

(continued)

BFN-UNIT 2 5.0-9 Amendment No. 253