Text

Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie Modification to Support System Operability (BFN-TS-518)
	ML21309A038
Person / Time
Site:	Browns Ferry
Issue date:	11/05/2021
From:	Polickoski J; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CNL-21-020
	Download: ML21309A038 (51)
	v • d • e

1101 Market Street, Chattanooga, Tennessee 37402 CNL-21-020 November , 2021 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 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 - Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie Modification to Support System Operability (BFN-TS-518)

In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.90, Application for amendment of license, construction permit, or early site permit, Tennessee Valley Authority (TVA) requests an amendment to the Renewed Facility Operating License (RFOL) Nos. DPR-33, DPR-52, and DPR-68 for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, respectively. The amendment proposes the use of a cross-tie between the BFN Unit 3 chilled water system and the BFN Units 1 and 2 chilled water system supplying the electric board room (EBR) air handling units (AHU). The use of the cross-tie will support operability of the BFN Units 1 and 2 EBR air conditioning systems and their supported electrical equipment.

Additionally, TVA is requesting a one-time use of a change to the BFN Technical Specifications (TS) 3.8.7, Distribution Systems - Operating, to allow for the installation of the cross-tie modification between the BFN Units 1 and 2 EBR AHUs and the BFN Unit 3 control bay chiller.

This TS change would allow the equipment in the Units 1 and 2 EBRs to remain operable while the cross-tie modification is completed and tested for operation. Once the cross-tie is installed and declared operational, this TS change would no longer be required.

The enclosure provides the description and technical evaluation of the proposed change, a regulatory evaluation, and a discussion of environmental considerations. Attachment 1 to the enclosure provides BFN Units 1, 2, and 3, Updated Final Safety Analysis Report pages marked up to show the proposed changes. Attachment 2 to the enclosure provides the BFN Units 1, 2, and 3 TS pages marked up to show the proposed changes. Attachment 3 to the enclosure provides the BFN Units 1, 2, and 3 TS pages retyped with the proposed changes.

U.S. Nuclear Regulatory Commission CNL-21-020 Page 2 November 5, 2021 TVA has determined that there is no significant hazards consideration associated with the proposed changes and that the changes to the RFOLs qualify 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), TVA is sending a copy of this letter and enclosure to the Alabama Department of Public Health.

TVA requests NRC approval of the proposed license amendment within one year from the date of this letter with implementation within 60 days following NRC approval.

There are no new regulatory commitments contained in this letter. Please address any questions regarding this submittal to Kimberly D. Hulvey, Senior Manager, Fleet Licensing at 423-751-3275.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 5th day of November 2021.

Respectfully, James T. Polickoski Director, Nuclear Regulatory Affairs

Enclosure:

Evaluation of the Proposed Change cc (Enclosure):

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

ENCLOSURE Evaluation of the Proposed Change Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3 - Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie Modification to Support System Operability (BFN-TS-518)

CNL-21-020

ENCLOSURE Evaluation of the Proposed Change

Subject:

Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie Modification to Support System Operability (BFN-TS-518)

TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION............................................................................................ 1 2.0 DETAILED DESCRIPTION ............................................................................................ 1 2.1 Reason for the Proposed Change .................................................................................. 1 2.2 Description of the Proposed Change .............................................................................. 2

3.0 TECHNICAL EVALUATION

........................................................................................... 5

4.0 REGULATORY EVALUATION

....................................................................................... 8 4.1 Applicable Regulatory Requirements .............................................................................. 8 4.2 No Significant Hazards Consideration Analysis............................................................... 9 4.3 Conclusions ................................................................................................................. 12

5.0 ENVIRONMENTAL CONSIDERATION

........................................................................ 12

6.0 REFERENCES

............................................................................................................ 12 Attachments:

1. Updated Final Safety Analysis Report Page Markups

2. Proposed TS Pages (Markups) for BFN Units 1,2,3

3. Proposed TS Bases Pages (Final Typed) for BFN Units 1,2,3 CNL-21-020

Enclosure 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend the Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, Renewed Facility Operating License Nos. DPR-33, DPR-52 and DPR-68. The requested amendment proposes the use of a cross-tie between the BFN Unit 3 control bay (CB) chilled water system and the BFN Unit 1/2 CB chilled water system supplying the electric board room (EBR) air handling units (AHUs). The use of the cross-tie will support operability of the BFN Unit 1 and Unit 2 EBR air conditioning system and their supported electrical equipment.

Additionally, TVA is requesting a one-time use technical specification (TS) change that provides an exception to the required actions of TS 3.8.7, Distribution Systems - Operating, during the installation and testing of the cross-tie. This would allow the equipment in the Units 1 and 2 EBRs to remain operable and would avoid entering multiple TS limiting condition for operation (LCO) conditions and their required actions during the installation and avoid a three-unit shutdown.

2.0 DETAILED DESCRIPTION 2.1 Reason for the Proposed Change The reason for the proposed amendment is to create a defense-in-depth strategy that supports operability of the Unit 1 and Unit 2 EBR air conditioning system by providing an alternate source of chilled water if both normal chilled-water sources are unavailable. In turn, this change reduces potential impacts to BFN Initiating Events.

On multiple occasions, BFN has experienced the loss of both Unit 1/2 CB chillers supporting the Unit 1 and Unit 2 EBR air conditioning system. In those cases, the EBR air conditioning losses required declaring the electrical equipment in the EBRs inoperable. The concurrent losses to safety-related equipment supported by the electric boards resulted in entering the required actions of TS LCO 3.0.3, applicable to Units 1, 2, and 3. In the two most recent instances, utilizing an alternate chilled-water source as proposed by this amendment would have allowed the Unit 1 and Unit 2 EBR air conditioning systems and their supported electrical equipment to remain OPERABLE.

Prior to the year 2000, the Unit 1 and Unit 2 EBRs were each independently cooled by two 100 percent capacity direct expansion (DX) air conditioning units. In 2000, implementation of a design change converted the Unit 1 and Unit 2 EBR DX air conditioning units to chilled-water AHUs and replaced the Unit 1/2 CB chillers. The single air-cooled chilled-water system serves nine local AHUs, including four AHUs for Unit 1 and Unit 2 EBRs. Because of this design change, the loss of two Unit 1/2 CB chillers immediately results in the inoperability of both Unit 1 and Unit 2 EBR air conditioning systems and the associated supported systems based on the TS definition of OPERABLE-OPERABILITY.

On July 14, 2015, and September 10, 2017, unplanned TS LCO entries were made when both Unit 1/2 CB chillers supporting the Units 1 and 2 main control room (MCR) air conditioning system (TS 3.7.4) and the Unit 1 and Unit 2 EBR air conditioning systems (Technical Requirements Manual (TRM) 3.7.6) were determined to be inoperable (References 1 and 2, respectively). Because the Unit 1/2 CB chilled water system provides heat removal for the air conditioning systems, the inoperability of both chillers results in a loss of essential cooling provided by the Unit 1 and Unit 2 EBR air conditioning systems and a loss of safety-related cooling capacity of the Units 1 and 2 MCR air conditioning system. An earlier instance occurred CNL-21-020 E1 of 12

Enclosure when the one chiller was inoperable and the other failed to start. After troubleshooting, the chiller that failed to start was successfully started before shutdown of units was required.

In conditions when both EBR air conditioning systems are inoperable, consistent with the TS definition of OPERABLE-OPERABILITY, the Technical Requirements Manual (TRM) requires immediately declaring the electrical equipment in the EBRs inoperable. This would result in entry into TS LCO 3.8.7, Distribution Systems - Operating, Conditions F (Unit 1) and G (Units 2 and 3). These TS LCO Conditions require, for each unit, with one or more required AC or DC boards inoperable, that the affected standby gas treatment (SGT) system or control room emergency ventilation (CREV) subsystem be declared inoperable immediately. In addition, BFN Units 1 and 2 would enter TS LCO 3.8.7, Conditions H (Unit 1) and I (Unit 2). These TS LCO Conditions require, with two or more electrical power distribution subsystems inoperable that result in a loss of function, that the affected unit enter TS LCO 3.0.3 immediately.

Note that with SGT A and B subsystems inoperable, BFN Units 1, 2, and 3, each would enter TS LCO 3.6.4.3, SGT System, Condition D. TS LCO Condition D requires that, with two or three SGT subsystems inoperable in MODE 1, 2, or 3, that the unit(s) enter TS LCO 3.0.3 immediately. As a result, BFN Units 1, 2, and 3, would enter TS LCO 3.0.3 with required action within one hour to initiate action to place Units 1, 2, and 3 in MODE 2 within 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , in MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and in MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . Thus, the proposed modification would provide a backup source of chilled water to the Units 1 and 2 EBR air conditioning systems and prevent placing Units 1, 2, and 3 in shutdown as described above.

The proposed amendment allows the use of the proposed modification and provides a one-time extended action completion time to restore the EBRs to provide time to install the cross-tie piping.

2.2 Description of the Proposed Change TVA proposes to install a manually operated chilled water cross-tie line from the Unit 3 CB chilled water system to the Unit 1/2 CB chilled water system to be used in the event of an abnormal condition when both trains of the Unit 1/2 CB chilled water system are inoperable.

This cross-tie line will meet the same seismic requirements as the current chilled water system piping, which is Class I seismic where appropriate. Operation of this cross-tie line will be performed by operations personnel when the Unit 1/2 CB chilled water system is inoperable (i.e., not providing sufficient chilled cooling water for its equipment loads). A simplified drawing of the proposed modification is provided in Figure 1.

CNL-21-020 E2 of 12

Enclosure Figure 1 BFN Control Bay Cooling Supply Configurations CNL-21-020 E3 of 12

Enclosure In order to support and reflect the proposed cross-tie modification, NRC review and approval are requested for the proposed changes to the Updated Final Safety Analysis Report (UFSAR) and TS.

1) TVA proposes to revise the BFN UFSAR, Section 10.12, HVAC Systems, and Appendix F, Unit Sharing and Interactions, to reflect the design modification and to incorporate licensing basis changes describing the Unit 3 CB chilled water system as both a shared system and as an alternate chilled-water source for Unit 1 and Unit 2 EBR AHUs.

UFSAR, Section 10.12 will be revised to identify that upon loss of both Unit 1/2 CB chillers, supplemental cooling is provided via cross-tie connecting Unit 3 CB chilled water system to the Unit 1 and Unit 2 EBR AHUs.

UFSAR Appendix F, Section F.7.11, will be revised to identify that the Unit 3 CB chilled water system is shared in that it can supply chilled water to the Unit 1 and Unit 2 EBR AHUs if needed.

Refer to Attachment 1 for the proposed BFN UFSAR markups as discussed above.

2) TVA requests NRC prior approval for a one-time only change to BFN Units 1, 2, and 3 TS 3.8.7, Distribution Systems - Operating. Several of the Conditions for TS 3.8.7 are updated to add the conditional phrase for reasons other than installation of the Unit 3 Control Bay Chiller Cross-tie when the compensatory actions of TVA letter CNL-21-020 are taken.

A new Condition (I for Unit 1, J for Units 2 and 3) and Note is also added that states:

NOTE---------------------------------------------

Only applicable on a one-time basis for installation and testing the Unit 3 Control Bay Chiller Cross-tie.

I. Two or more electrical power distributions subsystems inoperable due to installation of the Unit 3 Control Bay Chiller Cross-tie when the compensatory actions of TVA letter CNL-21-020 are taken.

Refer to Attachment 2 for the TS markups as discussed herein.

Installation is expected to last 43 hours4.976852e-4 days 0.0119 hours 7.109788e-5 weeks 1.63615e-5 months based on the estimated work steps required to install and leak check the prepared piping spool sections at the Units 1 and 2 chilled water piping.

Therefore, TVA is requesting an exception to the requirements of TS 3.8.7 for 2 days for installation so that essential cooling to the EBR AHUs can be temporarily isolated to complete the proposed cross-tie connections to the chilled-water piping. This is acceptable based on CB and EBR GOTHIC code analysis, which assumes a total loss of EBR cooling in Unit 1 or Unit 2 and defines the most limiting EBR heat up rate of 23.27 hours3.125e-4 days 0.0075 hours 4.464286e-5 weeks 1.02735e-5 months before reaching the design operating limit of 104 degrees Fahrenheit (°F). This is explained in more detail in Section 3.0.

An additional 7 days is also requested for flow-balancing the system with the Unit 3 chiller cross-tie aligned to the Unit 1 and Unit 2 EBR AHUs. During this time, the Unit 1 and Unit 2 CNL-21-020 E4 of 12

Enclosure EBR AHUs and the aligned Unit 3 CB chilled water system train will be available but will not be OPERABLE. The standby Unit 3 CB chilled water system train and both Unit 1/2 CB chilled water system trains remain OPERABLE. Because the limiting EBR takes approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to reach 104°F, there is ample time to realign the systems to their normal configurations before cooling is needed. Therefore, the requested time to complete the installation and testing and to restore the affected electrical power distribution subsystems to OPERABLE status is 9 days, 2 days for installation and 7 days for testing.

3.0 TECHNICAL EVALUATION

Providing an alternate backup source of cooling water via the cross-tie line to the Unit 1 and Unit 2 EBR AHU piping would allow BFN Units 1, 2, and 3 to continue to operate with the required cooling for all three units and prevent a potential three-unit shutdown when the Unit 1/2 CB chilled water system is unavailable. An available alternate cooling source for the Unit 1/2 EBR AHUs is proposed by the installation of an isolable cross-tie connecting chilled water from the Unit 3 CB chilled water system. The following technical evaluation discusses this proposed modification.

Cross-tie Use The rated certified capacity of each Unit 3 chiller including fouling factors is 112.5 tons. The current design-basis heat loads on the Unit 3 chiller total 74 tons, and the additional design basis heat loads from Unit 1 and Unit 2 EBRs increases the design requirement to 105.3 tons. This leaves approximately 7.2 tons of excess heat removal capacity.

The cross-tie modification does not result in a reduction of system or equipment redundancy, diversity, separation, or independence. The Unit 3 CB chilled water system consists of two 100-percent capacity trains. Each train is seismically-qualified where appropriate and has a safety-related power source, maintaining redundancy. No methods of cooling are being removed. Instead, a new method of cooling the Unit 1 and Unit 2 EBRs is added, maintaining diversity. The Unit 3 CB chilled water system will be isolable from the Unit 1/2 CB chilled water system, maintaining separation. This maintains independence of the different chilled water systems. Therefore, utilizing chilled water from the Unit 3 CB chilled water system to provide essential cooling for Unit 1 and Unit 2 EBR AHUs, does not affect BFNs compliance with General Design Criterion (GDC) 5, Sharing of structures, systems, and components, because sharing will not significantly impair its ability to perform its safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units.

Under normal circumstances, the Unit 1/2 CB chilled water system supplies these AHUs:

x Unit 1 EBRs - 2 AHUs @ 100 percent capacity each x Unit 2 EBRs - 2 AHUs @ 100 percent capacity each x Units 1 and 2 Main Control Room - 2 AHUs @ 100 percent capacity each x Units 1 and 2 Safety-related Equipment Rooms on EL 1 593 - 2 AHUs @ 100 percent capacity each x Common Switchyard Relay Room EL 617 ft - 1 AHU @ 100 percent capacity 1

Elevation about sea level expressed in feet.

CNL-21-020 E5 of 12

Enclosure and the Unit 3 CB chilled water system supplies these AHUs:

x Unit 3 Safety-related Equipment Rooms on EL 593 ft - 2 AHUs @ 100 percent capacity x Unit 3 Main Control Room & office spaces, EL 617 ft - 2 AHUs @ 100 percent capacity x Common Switchyard Relay Room, EL 617 ft - 1 AHU @ 100 percent capacity When the cross-tie is in use, the Unit 3 CB chilled water system will supply the Unit 1 and Unit 2 EBR AHUs in addition to its normal loads. Note that, as shown in Figure 1, the Unit 3 4kV and 480V shutdown board rooms are independently cooled by their own chilled-water or air conditioning system. The other Unit 1 and Unit 2 loads not served by the cross-tie, excluding the common switchyard relay room, which is already served by the Unit 3 CB chilled water system, are supplied by emergency direct expansion units when the Unit 1/2 CB chilled water system is unavailable. The emergency direct expansion units have a safety-related power source, are seismically-qualified, and have periodic preventive maintenance performed to maintain functionality.

Normally, the Unit 1 and Unit 2 EBR AHUs will be aligned to the Unit 1/2 CB chilled water system. When the Unit 3 CB chilled water cross-tie is needed, utilization of the cross-tie will require operators to isolate the Unit 1/2 CB chilled water system and align to the Unit 3 CB chilled water system via the cross-tie line. Alignment of the proposed cross-tie would involve manually manipulating several valves that are readily accessible in the control building. This valve manipulation would be similar to swapping chiller trains or the local startup of the emergency CB chiller unit. Based on the CB and EBR GOTHIC Analysis, which assumes a total loss of EBR cooling in Units 1 or 2, the most limiting EBR heat up rate is 23.27 hours3.125e-4 days 0.0075 hours 4.464286e-5 weeks 1.02735e-5 months before reaching the design operating limit of 104°F. Therefore, alignment of the proposed cross-tie would not be a time critical evolution.

After implementing the Unit 3 CB chilled water system cross-tie, TRM LCO 3.7.6 Action B.1, Declare the electrical equipment in the [EBRs] inoperable, would not be required if at least one Unit 3 chiller is available to provide cooling to the Unit 1 and Unit 2 EBR AHUs. Instead, the Unit 1 or Unit 2 MCR will inform the Unit 3 MCR that both Unit 1/2 CB chillers are inoperable and implementation of the Unit 3 cross-tie is required. The units would coordinate an implementation plan in accordance with BFN Operating Instructions.

Although the equipment in the Unit 1 and Unit 2 EBRs would remain OPERABLE, the Unit 1/2 MCR air conditioning systems would be inoperable. Units 1 and 2 would enter TS LCO 3.7.4, Conditions A and B. Condition A required action with one Unit 1/2 MCR air conditioning subsystem inoperable is to restore Unit 1/2 MCR air conditioning subsystem to OPERABLE status with a completion time of 30 days. Condition B required actions with two Unit 1/2 MCR air conditioning subsystems inoperable is to immediately initiate action to restore one Unit 1 and 2 MCR air conditioning subsystem to OPERABLE status, to place an alternate method of MCR cooling in operation within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and to restore one MCR air conditioning subsystem to OPERABLE status within 7 days. Thus, with both trains of Unit 1/2 CB chilled water system inoperable, the use of the cross-tie is limited to 7 days.

BFN Unit 3 chiller performance is verified by performing TS Surveillance Requirement (SR) 3.7.4.1, which ensures that the CB air conditioning system has the capability to remove the assumed heat load to maintain the required environmental conditions for plant operators and safety-related equipment by verifying proper chilled water temperatures and chilled water flows.

CNL-21-020 E6 of 12

Enclosure The SR verifies that the heat removal capability of the system is sufficient to remove the MCR heat load assumed in the safety analyses. This SR consists of a combination of testing and calculation, both of which will be revised as necessary to include the additional heat loads imposed by the Unit 1 and Unit 2 EBRs via the proposed cross-tie. The SR 3.7.4.1 is performed in accordance with the Surveillance Frequency Control Program.

Therefore, based on the above discussion, use of the cross-tie does not impair the systems ability to perform its safety function. Additionally, use of the cross-tie prevents the unnecessary shutdown of all three units in the event that both trains of the Unit 1/2 CB chilled water system are inoperable.

Cross-tie Installation Connecting the Unit 3 CB chilled water system to the Unit 1 and Unit 2 EBR AHUs requires temporarily isolating the Unit 1 and Unit 2 EBR AHUs from the Unit 1/2 CB chilled water system.

During this evolution, the Unit 1/2 CB chilled water system continues to supply chilled water to the Unit 1 and 2 MCR AHUs and the EL 593 ft AHUs (see Figure 1). Therefore, the Units 1 and 2 MCR air conditioning subsystems will remain OPERABLE during the evolution. Additionally, the equipment on EL 593 ft and the switchyard relay room will continue to be cooled. Therefore, the only cooling consideration is for the Unit 1 and Unit 2 EBRs.

Current analysis indicates that the Unit 1 and Unit 2 EBRs will not reach the design operating limit of 104°F for approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during a design-basis accident when no cooling is provided to the EBRs, the doors are closed, and the reactor building is already at 127°F. During the 43-hour cross-tie installation, the piping to the EBR AHUs will be open to the atmosphere for approximately 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months and available for use within 20 to 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months after opening the system.

This includes connecting both the supply and return lines to the cross-tie. This is less than the approximate 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the EBRs to heat up to 104°F when no action is taken to provide cooling to the rooms.

Additionally, BFN will take the following compensatory actions during installation of the Unit 3 CB chilled water crosstie to reduce risk:

x Remove missile hazards from the switchyard preferably by removing any trucks that may be present. If work trucks are found in the switchyard, remove potential missile hazards from the associated work trucks, and remove the trucks from the area if it is deemed safe to do so. If moving the trucks is deemed to be a higher risk than to secure them in place, document the assessment in the narrative logs.

x No work will be allowed in the switchyard or transformer yard. Shift manager permission is required for all access into the switchyard or transformer yard; these permission rights cannot be delegated. Remove potential missile threats from the switchyard and transformer yard.

x No planned electrical system AC or DC work will be authorized. Shift manager permission is required for all emergent electrical system AC or DC work during installation of the crosstie; these permission rights cannot be delegated.

x While the work will be planned to avoid predicted severe weather, in the case of severe weather, monitor plant areas for flying debris hazards every shift, in accordance with plant procedures.

x Monitor the ambient air temperature in the 1A, 1B, 2A, and 2B EBRs and their associated 480V shutdown board rooms twice per shift and document the temperatures in the narrative logs. If the temperatures in these board rooms exceed 100°F, open the CNL-21-020 E7 of 12

Enclosure associated board room doors and install fans to assist in maintaining the associated temperatures below 100°F. Do not block open the electric board room doors unless their ambient air temperature exceeds 100°F.

x Maintain one train of the Unit 1/2 CB chillers in operation.

x No hot work in the plant is authorized during this period.

x No high-risk activities are authorized during this period.

Given the above compensatory actions, and the time required for the EBRs to heat up to the design operating temperature of the equipment in the EBRs, there is reasonable assurance of the public health and safety during the cross-tie installation.

Cross-tie Testing and Flow-balancing After installation, flow-balancing the system is required with the Unit 3 chiller cross-tie aligned to the Unit 1 and Unit 2 EBR AHUs. During this time, the Unit 1 and Unit 2 EBR AHUs and the aligned Unit 3 CB chilled water system train will be available but will not be OPERABLE because chilled water flow to the EBR AHUs and other Unit 3 CB chilled water system loads is varying while it is adjusted to design values. The standby Unit 3 CB chilled water system train (the train not being flow-balanced at the time) and both Unit 1/2 CB chilled water system trains remain OPERABLE. Because the limiting EBR takes approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to reach 104°F, there is ample time to realign the systems to their normal configurations before cooling is needed.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements Design Criteria During the construction permit licensing process, each of the three BFN units was evaluated against the then-current draft of the Atomic Energy Commission (AEC) Proposed General Design Criteria. Units 1 and 2 were evaluated against the AEC-27 Criteria, while Unit 3 was evaluated against the AEC-70 Criteria. Although neither version of these proposed criteria had been adopted as regulatory requirements, the design, material procurement, and fabrication of each reactor unit was responsive to the respective applicable criteria for a construction permit.

Although the later criteria (AEC-70) did not wholly complement the earlier AEC-27 criteria, and also contained many aspects which could have been modified or clarified before their formal adoption, the design bases of each unit were reevaluated (at the time of initial Final Safety Analysis Report preparation) against the draft of the AEC-70 criteria current at the time of operating license application.

Based on the understanding of the intent of the proposed criteria current at the time of operating license application, it was concluded that each BFN unit conforms to the intent of the AEC General Design Criteria for Nuclear Power Plant Construction Permits.

Criterion 5Sharing of structures, systems, and components. Structures, systems, and components important to safety shall not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units.

CNL-21-020 E8 of 12

Enclosure During normal cooling, all heat loads for the Unit 1/2 CB Chilled Water System are isolated from the Unit 3 CB chilled water system. In the event that both trains of the Unit 1/2 CB chilled water system are inoperable, emergency backup cooling is provided to the Unit 1 and 2 MCR and the safety-related equipment along the EL 593 ft hallway. However, no backup cooling is available for the Unit 1 and 2 EBRs.

The Unit 3 CB chilled water system is being modified so that, if both trains of the Unit 1/2 CB chilled water system are inoperable, the Unit 3 CB chilled water system can provide adequate heat removal capability for its safety-related heat loads in addition to those for the Unit 1 and 2 EBRs. This modification is acceptable based upon design analysis and will be confirmed by periodic surveillance testing. The Unit 3 CB chilled water system has access to both normal and emergency power and, where appropriate, is designed to Class I seismic requirements.

Also, Unit 3 does not rely on the Unit 3 CB chilled water system for EBR or 4kV shutdown board room cooling required for orderly shutdown and cooldown; this is accomplished independently with redundant air conditioning systems and chillers, respectively. Therefore, sharing the Unit 3 CB chilled water system in this capacity will not impair the ability of the system to perform its safety functions while simultaneously performing the safety functions associated with the Unit 1/2 EBR AHUs.

4.2 No Significant Hazards Consideration Analysis The requested amendment proposes the use of a cross-tie between the BFN Unit 3 CB chilled water system and the BFN Unit 1/2 CB chilled water system supplying the EBR AHUs. The use of the cross-tie will support operability of the BFN Unit 1 and Unit 2 EBR air conditioning system and their supported electrical equipment.

Additionally, TVA is requesting a one-time use TS change that provides an exception to the Required Actions of TS 3.8.7, Distribution Systems - Operating, during the installation and testing of the cross-tie. This would allow the equipment in the Units 1 and 2 EBRs to remain operable and would avoid entering multiple TS LCO conditions and their required actions during the installation and avoid a three-unit shutdown.

A written evaluation of the significant hazards consideration of a proposed license amendment is required by Title 10 of the Code of Federal Regulations (CFR) 50.92. According to 10 CFR 50.92, a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

x Involve a significant increase in the probability or consequences of an accident previously evaluated; or x Create the possibility of a new or different kind of accident from any accident previously evaluated; or x Involve a significant reduction in a margin of safety.

As required by 10 CFR 50.91(a), the TVA analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is presented below.

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

Response: No CNL-21-020 E9 of 12

Enclosure The BFN CB chillers are not discussed in any accident or transient currently evaluated in the Updated Final Safety Analysis Report (UFSAR) (Chapter 14). The chillers, air conditioning systems or their control systems are not initiators of any accident evaluated in the UFSAR. A failure of a chiller system does not contribute to the frequency of occurrence of an accident.

Implementation of the proposed cross-tie modification makes it possible for the both the Unit 1/2 CB chilled water system and the Unit 3 CB chilled water system to provide essential cooling for the Unit 1 and Unit 2 EBR AHUs. This ability increases the reliability of the EBR air conditioning system and ensures the availability of electrical equipment relied upon for accident mitigation.

The proposed changes do not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes do not adversely affect the ability of structures, systems, and components to perform their intended safety function to mitigate the consequences of an initiating event within the assumed limits. The proposed changes do not affect the source term, containment isolation, or radiological consequences of any accident previously evaluated. Further, the proposed changes do not increase the types and the amounts of radioactive effluent that may be released, nor significantly increase individual or cumulative occupation/public radiation exposures.

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

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

Response: No Chillers and their associated piping and components are not initiators of accident scenarios. The cross-tie piping is not fundamentally different from the existing chilled-water piping. Without a credible accident initiator, a new accident cannot be created due to a failure of the chillers or piping. Therefore, this activity does not create the possibility for an accident of a different type than any previously evaluated in the UFSAR.

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 Unit 3 chillers each have a rated capacity of 112.5 tons. The current design-basis heat loads on the Unit 3 chiller are 74 tons. The additional design-basis heat loads from Units 1 and 2 EBRs increases the design requirement to 105.3 tons.

This leaves approximately 7.2 tons of excess heat removal capacity.

CNL-21-020 E10 of 12

Enclosure BFN Unit 3 chiller performance is verified via SR 3.7.4.1. The procedure used ensures that the Unit 3 control room air conditioning system has the capability to remove the assumed heat load to maintain the required environmental conditions for plant operators and safety-related control equipment by verifying proper chilled water temperatures and chilled water flows. The testing in the procedure verifies that the heat removal capability of the system is sufficient to remove the MCR heat load assumed in the safety analyses. This procedure consists of a combination of testing and calculation, both of which will be revised as necessary to include the additional design-basis heat loads from the Unit 1 and Unit 2 EBRs via the cross-tie.

The design modification will be consistent with the design requirements for the control building HVAC system. The cross-tie piping and components will be safety-related and seismically-qualified where appropriate. The Unit 3 CB chilled water system is safety-related and is seismically-qualified where appropriate. The U3 CB chillers have the capacity, with sufficient design margin, to absorb the additional design-basis accident heat loads to maintain the Units 1 and 2 reactor building EL 593 ft and EBR temperatures within acceptable limits for operation of equipment and for uninterrupted safe occupancy.

Unlike Units 1 and 2, essential cooling for the Unit 3 4-kiloVolt (KV) electric boards and 480 Volt (V) shutdown boards are independent from the Unit 3 CB chilled water system. The 4-kV electric boards for Unit 3 are located in rooms within the Unit 3 diesel generator building and are cooled by redundant air-conditioning units. The rooms containing the Unit 3 480V shutdown boards are cooled by two 100 percent capacity air-conditioning units located in the Unit 3 reactor building. Therefore, the reduction in design margin for the Unit 3 CB chilled water system as a result of the design-basis heat loads from the Units 1 and 2 EBR AHUs does not impair the ability of Unit 3 to safely shutdown the reactor (Unit 3) or maintain it in a safe shutdown condition. Additionally, the cross-tie will not be used as an alternate chilled water source for the Unit 3 CB chiller loads. Therefore, margin for the control bay chillers for Units 1 and 2 is maintained.

As stated with Nuclear Energy Institute (NEI) guidance NEI 96-07, Revision 1, Guidelines for 10 CFR 50.59 Evaluation, Section 4.3.2, a change, which may reduce system/equipment redundancy, diversity, separation or independence would require prior NRC approval. However, in this case, the proposed cross-tie modification does not result in a reduction of system/equipment redundancy, diversity, separation or independence. Adequate design margin and system redundancy is maintained. Therefore, utilizing chilled water from the Unit 3 CB chilled water system to provide cooling for Unit 1 and Unit 2 EBR AHUs, does not negatively affect BFNs compliance with GDC 5, Sharing of structures, systems, and components, because its safety function is not impaired by the sharing of these chilled water systems between units. However, because unit sharing in this capacity is not currently identified in the licensing basis, BFN is seeking NRC prior approval via this license amendment request to implement and utilize the proposed design modification to maintain operability of the Unit 1 and Unit 2 EBR air conditioning system.

Therefore, the proposed changes associated with this license amendment request do not involve a significant reduction in margin of safety.

CNL-21-020 E11 of 12

Enclosure Based on the above, it is concluded 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.

4.3 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 Commissions 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, or would change an inspection or surveillance requirement. 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 radioactive 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. Licensee Event Report 50-259/2015-003-00, Loss of Cooling to the Unit 1 and Unit 2 Shutdown Board Rooms Due To Fouled Chiller Coils, dated September 14, 2015 (ML15257A131)

2. Licensee Event Report 50-259/2017-004-00, Safety System Functional Failures Due to the lnoperability of Both Unit 1 and 2 Control Bay Chillers, dated November 9, 2017 (ML17313A848)

CNL-21-020 E12 of 12

Attachment 1 Updated Final Safety Analysis Report 3DJH0DUNXSV CNL-21-020

BFN-22 The control room air handling units provide ventilation to the main control room area.

Two 100-percent capacity air handling units are provided, each containing: heating and cooling coils, a humidifier, controls, and motor-operated dampers. The dampers isolate the air handling unit when on standby. The air handling cooling coils are equipped with vent and drain valves. Room return air is proportionally mixed with fresh air by manual dampers and filtered by renewable media filter cells rated at 85-percent NBS.

Fresh air is mechanically supplied for makeup to air-conditioning systems, for ventilating system requirements, and for pressurizing the Control Building. Fresh air supply systems separately serve the Units 1 and 2 air-conditioned spaces except the Electric Board Rooms, the Unit 3 air-conditioned spaces except the electric board rooms and spreading rooms. Each of the air-conditioned spaces has two 100-percent capacity supply fans.

Each spreading room is ventilated by one 100-percent capacity fresh-air supply fan.

Two 100-percent capacity exhaust fans serve both spreading rooms. The fresh air is filtered. The air flow is balanced with the exhaust flow exceeding the total supply flow in order to prevent a positive pressure in the spreading rooms in relation to the Control Bay Habitability Zone (CBHZ) thus precluding the possibility of unfiltered air inleakage into the CBHZ. Dampers exist in the ventilation exhaust lines from the spreading rooms. Manual provisions exist to restart one spreading room ventilation system independent of the other.

Two 100-percent capacity, air-cooled, water-chilling units, located on the Unit 1 and 2 Diesel Generator Building roof, provide essential cooling for the Units 1 and 2 control bay air-conditioning systems.

Two 100-percent capacity chilled water pumps for Unit 3 are each designed to circulate water through a water cooled water chilling unit. Chilled water is then circulated through a chilled water piping loop to each air-handling unit's cooling coil.

The system is equipped with test wells for temperature monitoring.

Two 100-percent capacity hot water pumps are each designed to circulate water that is heated by a hot water generator located in the Unit 1 mechanical equipment room.

The hot water is circulated through a hot water piping loop to various air-handling unit heating coils and reheat coils mounted in branch air supply ducts.

To prevent overheating of essential electrical equipment as a result of loss of cooling due to failure of both water chillers serving Units 1 and 2, or by the rupture of the chilled water loops, supplementary cooling is provided. Water-cooled condensing units are connected to direct-expansion cooling coils mounted in each air-conditioning system return air separate duct. Condenser cooling water is taken from the Emergency Equipment Cooling Water System.

The Unit 3 control bay ventilation and heating instruments are strategically located to sense a mixture of return and supply air for optimum system performance.

To provide an alternative means of protection for the electrical equipment in the Unit 1 and 2 Electrical Board Rooms against the failure of both chillers, a cross-tie to the Unit 3 Control Bay Chilled Water System can be engaged to provide a redundant source of chilled water. The cross-tie connections are isolated through manual, normally-closed valves.10.12-6 There is adequate margin in the Unit 3 chillers to supply the cross-tie loads of the Units 1 and 2 Electrical Board Rooms air handling units in addition to the air handling units normally supplied by the Unit 3 chillers.

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Attachment

7HFKQLFDO6SHFLILFDWLRQ 3DJHV 5HW\SHG CNL-21-020

(3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3952 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. , are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 234 to Facility Operating License DPR-33, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 234. For SRs that existed prior to Amendment 234, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 234.

BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. ___

Distribution Systems - Operating 3.8.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Unit 1 and 2 4.16 kV -------------------NOTE----------------

Shutdown Board Enter applicable Conditions and inoperable, for reasons Required Actions of Condition B, other than installation of C, and F when Condition A the Unit 3 Control Bay results in no power source to a Chiller Cross-tie when the required 480 volt board.

compensatory actions of --------------------------------------------

TVA letter CNL-21-020 are taken.

A.1 Restore the Unit 1 and 2 5 days 4.16 kV Shutdown Board to OPERABLE status. AND 12 days from discovery of failure to meet LCO AND A.2 Declare associated diesel Immediately generator inoperable.

(continued)

BFN-UNIT 1 3.8-34 Amendment No. 234, 254, ___

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One Unit 1 480 V B.1 Restore Board to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Shutdown Board OPERABLE status.

inoperable, for reasons AND other than LQVWDOODWLRQRI the Unit 3Control Bay 12 days from Chiller Cross-tie when the discovery of failure compensatoryactions of to meet LCO TVA letterCNL-21-020 are taken.

OR 480 V RMOV Board 1A inoperable, for reasons other than LQVWDOODWLRQRI the Unit 3Control Bay Chiller Cross-tie when the compensatoryactions of TVA letterCNL-21-020 are taken.

OR 480 V RMOV Board 1B inoperable, for reasons other than LQVWDOODWLRQRIthe Unit 3Control Bay Chiller Cross-tie when the compensatoryactions of TVA letterCNL-21-020 are taken.

C. One Unit 1 and 2 DG C.1 Restore Unit 1 and 2 DG 5 days Auxiliary Board inoperable. Auxiliary Board to OPERABLE status. AND 12 days from discovery of failure to meet LCO (continued)

BFN-UNIT 1 3.8-35 Amendment No. 234, 254, ___

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One Unit DC Board D.1 Restore required Board or 7 days inoperable, for reasons other Shutdown Board DC than LQVWDOODWLRQRIthe Unit 3 Distribution Panel to AND Control BayChiller Cross-tie OPERABLE status.

when thecompensatory 12 days from actions of TVAletter discovery of failure CNL-21-020 are taken. to meet LCO OR One Unit 1 and 2 Shutdown Board DC Distribution Panel inoperable, for reasons other than LQVWDOODWLRQRIthe Unit 3 Control BayChiller Cross-tie when thecompensatory actions of TVAletter CNL-21-020 are taken.

OR 250 V DC RMOV Board 1A inoperable, for reasons other than LQVWDOODWLRQRIthe Unit 3 Control BayChiller Cross-tie when thecompensatory actions of TVAletter CNL-21-020 are taken.

OR 250 V DC RMOV Board 1B inoperable, for reasons other than LQVWDOODWLRQRIthe Unit 3 Control BayChiller Cross-tie when thecompensatory actions of TVAletter CNL-21-020 are taken.

OR 250 V DC RMOV Board 1C inoperable, for reasons other than LQVWDOODWLRQRIthe Unit 3 Control BayChiller Cross-tie when thecompensatory actions of TVAletter CNL-21-020 are taken.

(continued)

BFN-UNIT 1 3.8-36 Amendment No. 234, 254, ___

Distribution Systems - Operating 3.8.7 CONDITION REQUIRED ACTION COMPLETION TIME E. Unit 1 and 2 4.16 kV -------------------NOTE----------------

Shutdown Board A and B Enter applicable conditions and inoperable, for reasons required actions of Condition B, other than LQVWDOODWLRQRI C, and F when Condition E the Unit 3Control Bay results in no power source to a Chiller Cross-tie when the required 480 volt board.

compensatoryactions of --------------------------------------------

TVA letterCNL-21-020 are taken. E.1 Restore one 4.16 kV 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Shutdown Board to OR OPERABLE status. AND Unit 1 and 2 4.16 kV 12 days from Shutdown Board C and D discovery of inoperable, for reasons failure to meet other than LQVWDOODWLRQRI LCO the Unit 3Control Bay Chiller Cross-tie when the compensatoryactions of TVA letterCNL-21-020 are taken.

F. One or more required F.1 Declare the affected SGT Immediately Unit 2 or 3 AC or DC or CREV subsystem Boards inoperable, for inoperable.

reasons other than LQVWDOODWLRQRItheUnit 3 Control Bay ChillerCross-tie when thecompensatory actions ofTVA letter CNL-21-020 aretaken.

G. Required Action and G.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, AND C, D, E, or I not met.

G.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

BFN-UNIT 1 3.8-3 Amendment No. 234, 254, ___

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. Two or more electrical H.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of function, for reasons other than LQVWDOODWLRQRIthe Unit 3 Control BayChiller Cross-tie when the compensatory actions of TVA letter CNL-21-020 are taken.

NOTE---------------

Only applicable one a one

time basis for installation and testing the Unit 3 Control Bay Chiller Cross-tie.

I. 7ZRRUPRUHHOHFWULFDO I.1 Restore affected electrical 9 days SRZHUGLVWULEXWLRQ power distribution subsystems inoperable subsystems to due to installation of the OPERABLE status.

Unit 3 Control bay Chiller Cross-tie when the compensatory actions of TVA letter CNL-21-020 are taken.

BFN-UNIT 1 3.8-37a Amendment No. 234, 254, ___

sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3952 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 000, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 253 to Facility Operating License DPR-52, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 253. For SRs that existed prior to Amendment 253, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 253.

(3) The licensee is authorized to relocate certain requirements included in Appendix A and the former Appendix B to licensee-controlled documents.

Implementation of this amendment shall include the relocation of these requirements to the appropriate documents, as described in the licensee's BFN-UNIT 2 Renewed License No. DPR-52 Amendment No. ___

Distribution Systems - Operating 3.8.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Unit 1 and 2 4.16 kV -------------------NOTE----------------

Shutdown Board Enter applicable Conditions and inoperable, for reasons Required Actions of Condition B, other than installation of C, D, and G when Condition A the Unit 3 Control Bay results in no power source to a Chiller Cross-tie when the required 480 volt board.

compensatory actions of --------------------------------------------

TVA letter CNL-21-020 are taken.

A.1 Restore the Unit 1 and 2 5 days 4.16 kV Shutdown Board to OPERABLE status. AND 12 days from discovery of failure to meet LCO AND A.2 Declare associated diesel Immediately generator inoperable.

(continued)

BFN-UNIT 2 3.8-34 Amendment No. 253, ___

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One Unit 2 480 V -------------------NOTE----------------

Shutdown Board Enter Condition C when inoperable, for reasons Condition B results in no power other than installation of source to 480 volt RMOV board the Unit 3 Control Bay 2D or 2E.

Chiller Cross-tie when the --------------------------------------------

compensatory actions of

TVA letter CNL-21-020 B.1 Restore Board to are taken. OPERABLE status. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OR AND 480 V RMOV Board 2A 12 days from inoperable, for reasons discovery of other than installation of failure to meet the Unit 3 Control Bay LCO Chiller Cross-tie when the

compensatory actions of

TVA letter CNL-21-020

are taken.

OR 480 V RMOV Board 2B

inoperable, for reasons

other than installation of

the Unit 3 Control Bay

Chiller Cross-tie when the

compensatory actions of

TVA letter CNL-21-020

are taken.

(continued)

BFN-UNIT 2 3.8-35 Amendment No. 253, ___

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Unit 2 480 V RMOV C.1 Declare the affected RHR Immediately Board 2D inoperable, for subsystem inoperable.

reasons other than

installation of the Unit 3

Control Bay Chiller

Cross-tie when the

compensatory actions of

TVA letter CNL-21-020

are taken.

OR Unit 2 480 V RMOV

Board 2E inoperable, for

reasons other than

installation of the Unit 3

Control Bay Chiller

Cross-tie when the

compensatory actions of

TVA letter CNL-21-020

are taken.

D. One Unit 1 and 2 DG D.1 Restore Unit 1 and 2 DG 5 days Auxiliary Board Auxiliary Board to inoperable. OPERABLE status. AND 12 days from discovery of failure to meet LCO (continued)

BFN-UNIT 2 3.8-35a Amendment No. 253, ___

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. One Unit DC Board E.1 Restore required Board or 7 days inoperable, for reasons Shutdown Board DC other than installation of Distribution Panel to AND the Unit 3 Control Bay OPERABLE status.

Chiller Cross-tie when the 12 days from compensatory actions of discovery of TVA letter CNL-21-020 failure to meet are taken. LCO OR One Unit 1 and 2

Shutdown Board DC

Distribution Panel

inoperable, for reasons

other than installation of

the Unit 3 Control Bay

Chiller Cross-tie when the

compensatory actions of

TVA letter CNL-21-020

are taken.

OR 250 V DC RMOV Board

2A inoperable, for

reasons other than

installation of the Unit 3

Control Bay Chiller

Cross-tie when the

compensatory actions of

TVA letter CNL-21-020

are taken.

OR (continued)

BFN-UNIT 2 3.8-36 Amendment No. 253, ___

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. (continued) 250 V DC RMOV Board 2B inoperable, for reasons other than installation of the Unit 3 Control Bay Chiller Cross-tie when the compensatory actions of TVA letter CNL 020 are taken.

OR 250 V DC RMOV Board 2C inoperable, for reasons other than installation of the Unit 3 Control Bay Chiller Cross-tie when the compensatory actions of TVA letter CNL 020 are taken.

(continued)

BFN-UNIT 2 3.8-36a Amendment No. 253, ___

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Unit 1 and 2 4.16 kV -------------------NOTE----------------

Shutdown Board A and B Enter applicable conditions and inoperable, for reasons other required actions of Condition B, C, D, than installation of the Unit 3 and G when Condition F results in no Control Bay Chiller Cross-tie power source to a required 480 volt when the compensatory board.

actions of TVA letter --------------------------------------------

CNL-21-020 are taken.

F.1 Restore one 4.16 kV 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OR Shutdown Board to OPERABLE status. AND Unit 1 and 2 4.16 kV Shutdown Board C and D 12 days from inoperable, for reasons other discovery of failure than installation of the Unit 3 to meet LCO Control Bay Chiller Cross-tie when the compensatory actions of TVA letter CNL-21-020 are taken.

G. One or more required Unit 1 G.1 Declare the affected SGT or Immediately or 3 AC or DC Boards CREV subsystem inoperable, for reasons other inoperable.

than installation of the Unit 3 Control Bay Chiller Cross-tie when the compensatory actions of TVA letter CNL-21-020 are taken.

H. Required Action and H.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, D, E, F or J not AND met.

H.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months I. Two or more electrical power I.1 Enter LCO 3.0.3. Immediately distribution subsystems inoperable that result in a loss of function, for reasons other than installation of the Unit 3 Control Bay Chiller Cross-tie when the compensatory actions of TVA letter CNL 020 are taken.

BFN-UNIT 2 3.8-37 Amendment No. 253, ___

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

NOTE---------------

Only applicable on a onetime basLs for installation and testing the Unit 3 Control Bay Chiller Cross-tie.

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BFN-UNIT 2 3.8-37a Amendment No. 253, 338, ___

(3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3952 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. , are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 212 to Facility Operating License DPR-68, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 212. For SRs that existed prior to Amendment 212, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 212.

BFN-UNIT 3 Renewed License No. DPR-68 Amendment No. ___

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. 8QLWN96KXWGRZQ -------------------NOTE----------------

%RDUG($DQG(% Enter applicable conditions and LQRSHUDEOH required actions of Condition B, C, D, and G when Condition F results 25 in no power source to a required 480 volt board.

8QLWN96KXWGRZQ

%RDUG(&DQG(' F.1 Restore one 4.16 kV 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months LQRSHUDEOH Shutdown Board to OPERABLE status. AND 12 days from discovery of failure to meet LCO G. 2QHRUPRUHUHTXLUHG G.1 Declare the affected SGT Immediately 8QLWRU$&RU'& or CREV subsystem

%RDUGVLQRSHUDEOHIRU inoperable.

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H. 5HTXLUHG$FWLRQDQG H.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months DVVRFLDWHG&RPSOHWLRQ

7LPHRI&RQGLWLRQ$% AND

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H.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months I. 7ZRRUPRUHHOHFWULFDO I.1 Enter LCO 3.0.3. Immediately SRZHUGLVWULEXWLRQ

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(continued)

BFN-UNIT 3 3.8-37 Amendment No. 212, ___

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

NOTE----------------

Only applicable on a onetime basis for installation and testing the Unit 3 Control Bay Chiller Cross-tie.

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BFN-UNIT 3 3.8-37a Amendment No. ___

v t e Letter Sequence Other
EPID:L-2021-LLA-0203, (Approved, Closed)
Initiation Acceptance, Acceptance Supplement, Supplement Administration Questions Answers Results Approval Other: CNL-21-020, Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie Modification to Support System Operability (BFN-TS-518), ML22168A080
MONTHYEAR2022-11-22 [Table View]

CNL-21-020, Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie Modification to Support System Operability (BFN-TS-518)

Text

Subject:

Enclosure:

Subject:

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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