CNL-21-090, Application to Adopt TSTF-568-A, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2, Revision 2 (BFN TS-539)

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Application to Adopt TSTF-568-A, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2, Revision 2 (BFN TS-539)
ML21323A125
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 11/19/2021
From: Polickoski J
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BFN TS-539, CNL-21-090
Download: ML21323A125 (26)
v • d • e


Text

1101 Market Street, Chattanooga, Tennessee 37402 CNL-21-090 November 19, 2021 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Browns Ferry Nuclear Plant Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Dockets 50-259, 50-260, and 50-296

Subject:

Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application to Adopt TSTF-568-A, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2, Revision 2 (BFN TS-539)

In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 10 CFR 50.90, Tennessee Valley Authority (TVA) is submitting for Nuclear Regulatory Commission (NRC) approval, a request for an amendment to Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant (BFN),

Units 1, 2, and 3.

TVA requests adoption of Technical Specification Task Force (TSTF) Traveler TSTF-568-A, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2, Revision 2. TSTF-568-A revises the Applicability and Actions of BFN Unit 1, 2, and 3, Technical Specification (TS) 3.6.2.6, Drywell-to-Suppression Chamber Differential Pressure, and TS 3.6.3.2, Primary Containment Oxygen Concentration, and presents the requirements in a manner more consistent with the Standard Technical Specifications (STS) format and content.

The Enclosure to this letter provides a description and assessment of the proposed change. provides the existing BFN Unit 1, 2, and 3 TS pages marked up to show the proposed changes. Attachment 2 provides revised (re-typed) BFN Unit 1, 2, and 3 TS pages. provides the existing BFN Unit 1 TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only (for purposes of this license amendment request (LAR), the BFN Units 1, 2, and 3 TS Bases are nearly identical).

U.S. Nuclear Regulatory Commission CNL-21-090 Page 2 November 19, 2021 TVA requests review of this amendment request under the Consolidated Line Item Improvement Process. Approval of the proposed amendment is requested within six-months from the date of this letter. Once approved, the amendment shall be implemented within 30 days.

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

There are no new regulatory commitments made in this letter.

Please address any questions regarding this submittal to Kimberly Hulvey, Senior Manager, Fleet Licensing, at 423-751-3275.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19th day of November 2021.

Respectfully, James T. Polickoski Director, Nuclear Regulatory Affairs

Enclosure:

Description and Assessment of the Proposed Change cc: 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

Enclosure Description and Assessment of the Proposed Change CNL-21-090

Enclosure Description and Assessment of the Proposed Change

Subject:

Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application to Adopt TSTF-568-A, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2, Revision 2 (BFN TS-539)

CONTENTS

1.0 DESCRIPTION

..................................................................................................................... 2 2.0 ASSESSMENT ..................................................................................................................... 2 2.1 Applicability of Safety Evaluation.................................................................................. 2 2.2 Optional Changes and Variations ................................................................................. 2

3.0 REGULATORY ANALYSIS

.................................................................................................. 2 3.1 No Significant Hazards Consideration Analysis ........................................................... 2 3.2 Conclusion .................................................................................................................... 4 4.0 ENVIRONMENTAL EVALUATION ....................................................................................... 4 Attachments 1 Proposed TS Pages (Markups) for BFN Unit 1, 2, and 3 2 Proposed TS Pages (Final Typed) for BFN Unit 1, 2, and 3 3 Proposed TS Bases Changes (For information only) for BFN Unit 1 CNL-21-090 E-1 of 4

Enclosure Description and Assessment of the Proposed Change

1.0 DESCRIPTION

Tennessee Valley Authority (TVA) requests adoption of Technical Specification Task Force (TSTF) Traveler TSTF-568-A, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2.

TSTF-568-A revises the Applicability and Actions of Browns Ferry Nuclear Plant (BFN) Unit 1, 2, and 3 Technical Specification (TS) 3.6.2.6, Drywell-to-Suppression Chamber Differential Pressure, and TS 3.6.3.2, Primary Containment Oxygen Concentration, and presents the requirements in a manner more consistent with the Standard Technical Specifications (STS) format and content.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation TVA has reviewed the safety evaluation for TSTF-568 provided to the Technical Specifications Task Force in a letter dated December 17, 2019. This review included a review of the Nuclear Regulatory Commission (NRC) staffs evaluation, as well as the information provided in TSTF-568-A. As described herein, TVA has concluded that the justifications presented in TSTF-568-A and the safety evaluation prepared by the NRC staff are applicable to BFN Units 1, 2, and 3 and justify this amendment for the incorporation of the changes to the BFN Unit 1, 2, and 3 TS.

2.2 Optional Changes and Variations The BFN TS utilize different numbering than the STS on which TSTF-568-A was based.

Specifically, STS 3.6.2.5 correlates with BFN TS 3.6.2.6. This difference is administrative in nature and does not affect the applicability of TSTF-568-A to the BFN TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis TVA requests adoption of TSTF-568-A, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2. TSTF-568-A revises the Applicability and Actions of BFN TS 3.6.2.6, Drywell-to-Suppression Chamber Differential Pressure, and TS 3.6.3.2, Primary Containment Oxygen Concentration, and presents the requirements in a manner more consistent with the STS format and content.

TVA has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in Title 10 of the Code of Federal Regulations (10 CFR) 50.92, Issuance of amendment, as discussed below.

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

Response: No The proposed change revises the Applicability and Actions of TS 3.6.2.6, Drywell-to-Suppression Chamber Differential Pressure, and TS 3.6.3.2, Primary Containment Oxygen Concentration, and presents the requirements in a manner more consistent CNL-21-090 E2 of 4

Enclosure Description and Assessment of the Proposed Change with the STS format and content. Drywell-to-suppression chamber differential pressure and primary containment oxygen concentration are not initiators to any accident previously evaluated. As a result, the probability of any accident previously evaluated is not affected by the proposed change.

Drywell-to-suppression chamber differential pressure and primary containment oxygen concentration are assumptions in the mitigation of some accidents previously evaluated.

The Applicability of TS 3.6.3.2 is changed from Mode 1 when thermal power is greater than 15% to Modes 1 and 2. This expands the Applicability of the TS and will not have an effect on the consequences of an accident. The existing Applicability exceptions are removed and replaced with a longer Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The consequences of an event that could affect the drywell-to-suppression chamber differential pressure and primary containment oxygen concentration are no different during the proposed Completion Time than the consequences of the same event during the existing Completion Times. A note referencing Limiting Condition for Operation (LCO) 3.0.4.c is added to the Actions to permit entering the Applicability with the LCO not met. The note replaces the existing Applicability exceptions. This change is administrative and has no effect on the consequences of an accident.

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

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

Response: No The proposed change revises the Applicability and Actions of TS 3.6.2.6, Drywell-to-Suppression Chamber Differential Pressure, and TS 3.6.3.2, Primary Containment Oxygen Concentration, and presents the requirements in a manner more consistent with the STS format and content. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed). No credible new failure mechanisms, malfunctions, or accident initiators that would have been considered a design basis accident in the Updated Final Safety Analysis Report are created because the NRC has determined that hydrogen generation is not risk significant for design basis accidents.

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

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

Response: No The proposed change revises the Applicability and Actions of TS 3.6.2.6, Drywell-to-Suppression Chamber Differential Pressure, and TS 3.6.3.2, Primary Containment Oxygen Concentration, and presents the requirements in a manner more consistent with the STS format and content. No safety limits are affected. No LCO or surveillance limits are affected. The Drywell-to-Suppression Chamber Differential Pressure and Primary Containment Oxygen Concentration technical specification requirements assure sufficient safety margins are maintained, and that the design, operation, CNL-21-090 E3 of 4

Enclosure Description and Assessment of the Proposed Change surveillance methods, and acceptance criteria specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plants' licensing bases. The proposed change does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety.

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

Based on the discussion 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.

3.2 Conclusion 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 NRC 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.

4.0 ENVIRONMENTAL EVALUATION The proposed license 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 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.

CNL-21-090 E4 of 4

Attachment 1 Proposed TS Pages (Markups) for BFN Unit 1, 2, and 3 (6 total pages)

CNL-21-090

Drywell-to-Suppression Chamber Differential Pressure 3.6.2.6 3.6 CONTAINMENT SYSTEMS 3.6.2.6 Drywell-to-Suppression Chamber Differential Pressure LCO 3.6.2.6 The drywell pressure shall be maintained t 1.1 psid above the pressure of the suppression chamber.

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

This differential may be decreased to < 1.1 psid for a maximum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during required operability testing of the HPCI system, the RCIC system or the suppression chamber-to-drywell vacuum breakers.

with THERMAL POWER > 15% RTP.

APPLICABILITY: MODE 1 during the time period:

a. From 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is > 15% RTP following startup, to
b. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing THERMAL POWER to < 15% RTP prior to the next scheduled reactor shutdown.

72 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell-to-suppression A.1 Restore differential 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> chamber differential pressure to within limit.

pressure not within limit.

B. Required Action and B.1 Reduce THERMAL 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion POWER to d 15% RTP.

Time not met.

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

LCO 3.0.4.c is applicable.

BFN-UNIT 1 3.6-38 Amendment No. 234

Primary Containment Oxygen Concentration 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Primary Containment Oxygen Concentration LCO 3.6.3.2 The primary containment oxygen concentration shall be < 4.0 volume percent.

S and 2.

APPLICABILITY: MODE 1 during the time period:

a. From 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is > 15% RTP following startup, to
b. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing THERMAL POWER to < 15% RTP prior to the next scheduled reactor shutdown.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 72 A. Primary containment A.1 Restore oxygen 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> oxygen concentration not concentration to within within limit. limit.

12 B. Required Action and B.1 Reduce THERMAL 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> associated Completion POWER to d 15% RTP.

Time not met.

Be in MODE 3.

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

LCO 3.0.4.c is applicable.

BFN-UNIT 1 3.6-42 Amendment No. 234

Drywell-to-Suppression Chamber Differential Pressure 3.6.2.6 3.6 CONTAINMENT SYSTEMS 3.6.2.6 Drywell-to-Suppression Chamber Differential Pressure LCO 3.6.2.6 The drywell pressure shall be maintained t 1.1 psid above the pressure of the suppression chamber.

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

This differential may be decreased to < 1.1 psid for a maximum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during required operability testing of the HPCI system, the RCIC system or the suppression chamber-to-drywell vacuum breakers.

with THERMAL POWER > 15% RTP.

APPLICABILITY: MODE 1 during the time period:

a. From 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is > 15% RTP following startup, to
b. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing THERMAL POWER to < 15% RTP prior to the next scheduled reactor shutdown.

72 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell-to-suppression A.1 Restore differential 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> chamber differential pressure to within limit.

pressure not within limit.

B. Required Action and B.1 Reduce THERMAL 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion POWER to d 15% RTP.

Time not met.

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

LCO 3.0.4.c is applicable.

BFN-UNIT 2 3.6-38 Amendment No. 253

Primary Containment Oxygen Concentration 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Primary Containment Oxygen Concentration LCO 3.6.3.2 The primary containment oxygen concentration shall be < 4.0 volume percent.

S and 2.

APPLICABILITY: MODE 1 during the time period:

a. From 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is > 15% RTP following startup, to
b. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing THERMAL POWER to < 15% RTP prior to the next scheduled reactor shutdown.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 72 A. Primary containment A.1 Restore oxygen 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> oxygen concentration not concentration to within within limit. limit.

12 B. Required Action and B.1 Reduce THERMAL 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> associated Completion POWER to d 15% RTP.

Time not met.

Be in MODE 3.

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

LCO 3.0.4.c is applicable.

BFN-UNIT 2 3.6-42 Amendment No. 253

Drywell-to-Suppression Chamber Differential Pressure 3.6.2.6 3.6 CONTAINMENT SYSTEMS 3.6.2.6 Drywell-to-Suppression Chamber Differential Pressure LCO 3.6.2.6 The drywell pressure shall be maintained t 1.1 psid above the pressure of the suppression chamber.

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

This differential may be decreased to < 1.1 psid for a maximum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during required operability testing of the HPCI system, the RCIC system or the suppression chamber-to-drywell vacuum breakers.

with THERMAL POWER > 15% RTP.

APPLICABILITY: MODE 1 during the time period:

a. From 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is > 15% RTP following startup, to
b. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing THERMAL POWER to < 15% RTP prior to the next scheduled reactor shutdown.

72 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell-to-suppression A.1 Restore differential 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> chamber differential pressure to within limit.

pressure not within limit.

B. Required Action and B.1 Reduce THERMAL 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion POWER to d 15% RTP.

Time not met.

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

LCO 3.0.4.c is applicable.

BFN-UNIT 3 3.6-38 Amendment No. 212

Primary Containment Oxygen Concentration 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Primary Containment Oxygen Concentration LCO 3.6.3.2 The primary containment oxygen concentration shall be < 4.0 volume percent.

S and 2.

APPLICABILITY: MODE 1 during the time period:

a. From 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is > 15% RTP following startup, to
b. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing THERMAL POWER to < 15% RTP prior to the next scheduled reactor shutdown.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 72 A. Primary containment A.1 Restore oxygen 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> oxygen concentration not concentration to within within limit. limit.

12 B. Required Action and B.1 Reduce THERMAL 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> associated Completion POWER to d 15% RTP.

Time not met.

Be in MODE 3.

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

LCO 3.0.4.c is applicable.

BFN-UNIT 3 3.6-42 Amendment No. 212

Attachment 2 Proposed TS Pages (Final Typed) for BFN Unit 1, 2, and 3 (6 total pages)

CNL-21-090

Drywell-to-Suppression Chamber Differential Pressure 3.6.2.6 3.6 CONTAINMENT SYSTEMS 3.6.2.6 Drywell-to-Suppression Chamber Differential Pressure LCO 3.6.2.6 The drywell pressure shall be maintained 1.1 psid above the pressure of the suppression chamber.

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

This differential may be decreased to < 1.1 psid for a maximum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during required operability testing of the HPCI system, the RCIC system or the suppression chamber-to-drywell vacuum breakers.

APPLICABILITY: MODE 1 with THERMAL POWER > 15% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

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

LCO 3.0.4.c is applicable.

A. Drywell-to-suppression A.1 Restore differential 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> chamber differential pressure to within limit.

pressure not within limit.

B. Required Action and B.1 Reduce THERMAL 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion POWER to 15% RTP.

Time not met.

BFN-UNIT 1 3.6-38 Amendment No. 234, ___

Primary Containment Oxygen Concentration 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Primary Containment Oxygen Concentration LCO 3.6.3.2 The primary containment oxygen concentration shall be < 4.0 volume percent.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

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

LCO 3.0.4.c is applicable.

A. Primary containment A.1 Restore oxygen 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> oxygen concentration not concentration to within within limit. limit.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met.

BFN-UNIT 1 3.6-42 Amendment No. 234, ___

Drywell-to-Suppression Chamber Differential Pressure 3.6.2.6 3.6 CONTAINMENT SYSTEMS 3.6.2.6 Drywell-to-Suppression Chamber Differential Pressure LCO 3.6.2.6 The drywell pressure shall be maintained 1.1 psid above the pressure of the suppression chamber.

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

This differential may be decreased to < 1.1 psid for a maximum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during required operability testing of the HPCI system, the RCIC system or the suppression chamber-to-drywell vacuum breakers.

APPLICABILITY: MODE 1 with THERMAL POWER > 15% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

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

LCO 3.0.4.c is applicable.

A. Drywell-to-suppression A.1 Restore differential 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> chamber differential pressure to within limit.

pressure not within limit.

B. Required Action and B.1 Reduce THERMAL 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion POWER to 15% RTP.

Time not met.

BFN-UNIT 2 3.6-38 Amendment No. 253, ___

Primary Containment Oxygen Concentration 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Primary Containment Oxygen Concentration LCO 3.6.3.2 The primary containment oxygen concentration shall be < 4.0 volume percent.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

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

LCO 3.0.4.c is applicable.

A. Primary containment A.1 Restore oxygen 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> oxygen concentration not concentration to within within limit. limit.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met.

BFN-UNIT 2 3.6-42 Amendment No. 253, ___

Drywell-to-Suppression Chamber Differential Pressure 3.6.2.6 3.6 CONTAINMENT SYSTEMS 3.6.2.6 Drywell-to-Suppression Chamber Differential Pressure LCO 3.6.2.6 The drywell pressure shall be maintained 1.1 psid above the pressure of the suppression chamber.

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

This differential may be decreased to < 1.1 psid for a maximum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during required operability testing of the HPCI system, the RCIC system or the suppression chamber-to-drywell vacuum breakers.

APPLICABILITY: MODE 1 with THERMAL POWER > 15% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

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

LCO 3.0.4.c is applicable.

A. Drywell-to-suppression A.1 Restore differential 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> chamber differential pressure to within limit.

pressure not within limit.

B. Required Action and B.1 Reduce THERMAL 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion POWER to 15% RTP.

Time not met.

BFN-UNIT 3 3.6-38 Amendment No. 212, ___

Primary Containment Oxygen Concentration 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Primary Containment Oxygen Concentration LCO 3.6.3.2 The primary containment oxygen concentration shall be < 4.0 volume percent.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

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

LCO 3.0.4.c is applicable.

A. Primary containment A.1 Restore oxygen 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> oxygen concentration not concentration to within within limit. limit.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met.

BFN-UNIT 3 3.6-42 Amendment No. 212, ___

Attachment 3 Proposed TS Bases Changes (For information only) for BFN Unit 1 (4 total pages)

CNL-21-090

Drywell-to-Suppression Chamber Differential Pressure B 3.6.2.6 BASES APPLICABLE Initial drywell-to-suppression chamber differential pressure SAFETY ANALYSES affects both the dynamic pool loads on the suppression (continued) chamber and the peak drywell pressure during downcomer pipe clearing during a Design Basis Accident LOCA.

Drywell-to-suppression chamber differential pressure must be maintained within the specified limits so that the safety analysis remains valid.

Drywell-to-suppression chamber differential pressure satisfies Criterion 2 of the NRC Policy Statement (Ref. 2).

LCO A drywell-to-suppression chamber differential pressure limit of 1.1 psid is required to ensure that the containment conditions assumed in the safety analyses are met. A drywell-to-suppression chamber differential pressure of < 1.1 psid corresponds to a downcomer water leg of > 1.04 ft. Failure to maintain the required differential pressure could result in excessive forces on the suppression chamber due to higher water clearing loads from downcomer vents and higher pressure buildup in the drywell. A Note permits the differential pressure to be decreased to < 1.1 psid for a maximum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during testing of the HPCI system, the RCIC system, or the suppression chamber-to-drywell vacuum breakers. with THERMAL POWER > 15% RTP APPLICABILITY Drywell-to-suppression chamber differential pressure must be controlled when the primary containment is inert. The primary containment must be inert in MODE 1, since this is the condition with the highest probability for an event that could produce hydrogen.

hydrogen It is also the condition with the highest probability of an event that could impose large loads on the primary containment.

(continued)

BFN-UNIT 1 B 3.6-87 Revision 0

Drywell-to-Suppression Chamber Differential Pressure B 3.6.2.6 BASES APPLICABILITY Inerting primary containment is an operational problem because (continued) it prevents primary containment access without an appropriate apparatus Therefore, breathing apparatus. Therefore the primary containment is inerted as late as possible in the unit startup and is de-inerted as soon as possible in the unit shutdown shutdown. As long as reactor power is < 15% RTP RTP, the probability of an event that generates hydrogen or excessive loads on primary containment occurring within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following a startup or within the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to a shutdown is low enough that these "windows,"

windows with the primary containment not inerted, inerted are also justified.

justified The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period is a reasonable amount of time to allow plant personnel to perform inerting or de-inerting de-inerting.

ACTIONS A.1 72 A Note permits the use of the provisions of LCO 3.0.4.c. This If drywell-to-suppression chamber differential pressure is not allowance permits entry into the within the limit, the conditions assumed in the safety analyses applicable MODE(S) while relying on are not met and the differential pressure must be restored to the ACTIONS. This allowance is within the limit within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time acceptable because inerting the provides sufficient time to restore differential pressure to within primary containment prevents limit and takes into account the low probability of an event that containment access without an would create excessive suppression chamber loads occurring appropriate breathing apparatus. during this time period.

Therefore, the primary containment is inerted as late as possible in the plant startup, after entering Mode 1 B.1 with THERMAL POWER > 15%

RTP, and de-inerted as soon as If the differential pressure cannot be restored to within limits possible in the plant shutdown. It within the associated Completion Time, the plant must be is acceptable to intentionally enter placed in a MODE in which the LCO does not apply. This is Required Action A.1 prior to a done by reducing power to d 15% RTP within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The shutdown in order to begin de-12 hour Completion Time is reasonable, based on operating inerting the primary containment prior to exiting the Applicability.

experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

(continued)

BFN-UNIT 1 B 3.6-88 Revision 0

Primary Containment Oxygen Concentration B 3.6.3.2 BASES (continued)

APPLICABLE The Reference 1 calculations assume that the primary SAFETY ANALYSES containment is inerted when a Design Basis Accident loss of coolant accident occurs. Thus, the hydrogen assumed to be released to the primary containment as a result of metal water reaction in the reactor core will not produce combustible gas mixtures in the primary containment. Oxygen, which is subsequently generated by radiolytic decomposition of water, is diluted and removed by the CAD System more rapidly than it is produced.

Primary containment oxygen concentration satisfies Criterion 2 of the NRC Policy Statement (Ref. 2).

LCO The primary containment oxygen concentration is maintained

< 4.0 v/o to ensure that an event that produces any amount of hydrogen does not result in a combustible mixture inside primary containment.

APPLICABILITY The primary containment oxygen concentration must be within the specified limit when primary containment is inerted, except as allowed by the relaxations during startup and shutdown addressed below below. The primary containment must be inert in MODE 1, since this is the condition with the highest probability of an event that could produce hydrogen.

and 2 Inerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus.

apparatus Therefore, Therefore the primary containment is inerted as late as possible in the plant startup and de-inerted as soon as possible in the plant shutdown shutdown. As long as reactor power is < 15% RTP RTP, the potential for an event that generates (continued)

BFN-UNIT 1 B 3.6-98 Revision 0

Primary Containment Oxygen Concentration B 3.6.3.2 BASES APPLICABILITY significant hydrogen is low and the primary containment need (continued) not be inert inert. Furthermore Furthermore, the probability of an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a startup, startup or within the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before a shutdown, shutdown is low enough that these "windows,"

windows when the primary containment is not inerted inerted, are also justified justified. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period is a reasonable amount of time to allow plant personnel to perform inerting or de-inerting de-inerting.

ACTIONS A.1 72 or 2 If oxygen concentration is t 4.0 v/o at any time while operating in MODE 1, with the exception off the relaxations allowed during startup and shutdown shutdown, oxygen concentration must be restored A Note permits the use of the to < 4.0 v/o within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is provisions of LCO 3.0.4.c. This allowed when oxygen concentration is t 4.0 v/o because of the allowance permits entry into the availability of other hydrogen mitigating systems (e.g., the CAD applicable MODE(S) while relying on System) and the low probability and long duration of an event the ACTIONS. This allowance is that would generate significant amounts of hydrogen occurring acceptable because inerting the during this period.

primary containment prevents containment access without an appropriate breathing apparatus. B.1 MODE 3 12 Therefore, the primary containment is inerted as late as possible in the If oxygen concentration cannot be restored to within limits within plant startup, after entering MODES the required Completion Time, the plant must be brought to a 1 and 2, and de-inerted as soon as MODE in which the LCO does not apply. To achieve this status, possible in the plant shutdown. It power must be reduced to d 15% RTP within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The is acceptable to intentionally enter 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time is reasonable, based on operating Required Action A.1 prior to a shutdown in order to begin de-experience, to reduce reactor power from full power conditions inerting the primary containment in an orderly manner and without challenging plant systems.

prior to exiting the Applicability.

(continued)

BFN-UNIT 1 B 3.6-99 Revision 0

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