CNL-22-007, Supplement to Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie Modification to Support System Operability (BFN-TS-518)

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Supplement to Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie Modification to Support System Operability (BFN-TS-518)
ML22096A328
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 04/06/2022
From: Jim Barstow
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-22-007, EPID L-2021-LLA-0203
Download: ML22096A328 (43)


Text

1101 Market Street, Chattanooga, Tennessee 37402 CNL-22-007 April 6, 2022 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 - Supplement to Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie Modification to Support System Operability (BFN-TS-518)

(EPID L-2021-LLA-0203)

References:

1. TVA Letter to NRC, CNL-21-020, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application Requesting NRC Prior Approval of a Proposed Chilled Water Crosstie Modification to Support System Operability, dated November 5, 2021 (ML21309A038)
2. NRC Electronic Mail to TVA, Acceptance Review Results for Browns Ferry Nuclear Plant, Units 1, 2, and 3, License Amendment Request to Revise TS 3.8.7 for Installation of the Control Bay Chiller Cross-Tie, dated December 9, 2021 (ML21349A226)

In Reference 1, Tennessee Valley Authority (TVA) submitted a request for an amendment to Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, respectively. 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 electrical board room (EBR) air handling units. 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.

In Reference 2, the Nuclear Regulatory Commission (NRC) issued the results of its decision accepting the requested amendment for review. Accompanying its decision, the NRC provided comments that require TVA response during the NRCs more detailed review of the application.

The enclosure to this letter provides TVAs responses to those comments.

U. S. Nuclear Regulatory Commission CNL-22-007 Page 2 April 6, 2022 to the enclosure has been provided in response to NRC Comment 1 of Reference 2. In response to NRC Comments 3 and 4 of Reference 2, TVA has provided updated proposed TS markups in Attachment 2 of the enclosure and retyped TS pages in . Attachments 2 and 3 of this submittal replace Attachments 2 and 3 of Reference 1 in their entirety.

This letter does not change the no significant hazards consideration, or the environmental considerations contained in Reference 1. Additionally, in accordance with 10 CFR 50.91(b)(1),

TVA is sending a copy of this letter and the enclosure to the Alabama Department of Public Health.

There are no new regulatory commitments contained in this letter. If you have any questions regarding this submittal, please contact Stuart L. Rymer, Senior Manager, Fleet Licensing at slrymer@nrc.gov.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 6th day of April 2022.

Respectfully, Digitally signed by Rearden, Pamela S

Date: 2022.04.06 16:08:03 -04'00' James Barstow Vice President, Nuclear Regulatory Affairs & Support Services

Enclosure:

Response to NRC Acceptance Review Comments 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 Department of Public Health

Enclosure Response to NRC Acceptance Review Comments On December 9, 2021, the Nuclear Regulatory Commission (NRC) provided its acceptance for review for Tennessee Valley Authoritys (TVA) license amendment request submitted in Reference 1. In the NRCs email communicating its acceptance, the following comments were provided:

during the staffs acceptance review, it identified the need for the following additional information, which are not considered sufficiency items:



x TS Bases (mark-up) pages were not provided (Note that in the Table of Contents for the Enclosure, Attachment 3s title indicates that Bases pages are included; however, Attachment 3 contains clean TS pages). The NRC staff notes that while 10 CFR 50.36(a)(1) does not explicitly describe the acceptable format of the required bases or reasons for such specifications, submission of Bases pages is one way to satisfy 10 CFR 50.36(a)(1).

x Clarification on whether the compensatory actions listed in the LAR will only be taken during the cross-tie installation period (2 days) or also during the testing period (7 days)

x Explanation of why the proposed wording modifying the existing Conditions and for new Condition I (Unit 1) and Condition J (Units 2 and 3) does not include language accounting for testing of the cross-tie

x Addition of a time limit or refueling outage date for the proposed Note for new Conditions I and J

Below is additional information TVA is providing to address the comments above. In response to NRC Comments 3 and 4 of Reference 2, TVA has provided updated proposed technical specifications (TS) markups in Attachment 2 of the enclosure and retyped TS pages in . Attachments 2 and 3 of this submittal replace Attachments 2 and 3 of Reference 1 in their entirety.

NRC Comment 1 TS Bases (mark-up) pages were not provided (Note that in the Table of Contents for the Enclosure, Attachment 3s title indicates that Bases pages are included; however, Attachment 3 contains clean TS pages). The NRC staff notes that while 10 CFR 50.36(a)(1) does not explicitly describe the acceptable format of the required bases or reasons for such specifications, submission of Bases pages is one way to satisfy 10 CFR 50.36(a)(1).

TVA Response of the license amendment request in Reference 1 was mislabeled in the Table of Contents. A condition report has been added to the TVA Corrective Action Program to track this issue. TS Bases pages were not initially intended to be included because the permanent change to the licensing basis is related to the Updated Final Safety Analysis Report regarding sharing of systems among units, and the Technical Specifications (TS) are only affected regarding installation and testing of the modification. However, Attachment 1 to this enclosure, provided for information only, contains TS Bases pages for Unit 1 marked to indicate the proposed changes. The changes for Units 2 and 3 are similar except for the letter identifiers for the conditions.

CNL-22-007 E1 of 2

Enclosure NRC Comment 2 Clarification on whether the compensatory actions listed in the LAR will only be taken during the cross-tie installation period (2 days) or also during the testing period (7 days)

TVA Response The compensatory actions listed in the license amendment request in Reference 1 will be taken during both the cross-tie installation period (2 days) and the testing period (7 days) for a total of 9 days.

NRC Comment 3 Explanation of why the proposed wording modifying the existing Conditions and for new Condition I (Unit 1) and Condition J (Units 2 and 3) does not include language accounting for testing of the cross-tie.

TVA Response to this enclosure provides updated proposed TS pages marked up to show that the one-time use TS change applies to both installation and testing. Other changes were also made to improve readability without changing the operation or intent of the TS change.

NRC Comment 4 Addition of a time limit or refueling outage date for the proposed Note for new Conditions I and J

TVA Response As shown in the attachments to this enclosure, an expiration date of October 1, 2025, was added for the one-time use TS change. This allows two full fiscal years after approval of the proposed license amendment to implement the design modification.

References

1. TVA Letter to NRC, CNL-21-020, Browns Ferry Nuclear Plant, Units 1, 2, and 3 -

Application Requesting NRC Prior Approval of a Proposed Chilled Water Crosstie Modification to Support System Operability, dated November 5, 2021 (ML21309A038)

2. NRC Electronic Mail to TVA, Acceptance Review Results for Browns Ferry Nuclear Plant, Units 1, 2, and 3, License Amendment Request to Revise TS 3.8.7 for Installation of the Control Bay Chiller Cross-Tie, dated December 9, 2021 (ML21349A226)

CNL-22-007 E2 of 2

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Distribution Systems - Operating B 3.8.7 BASES (continued) for reasons other ACTIONS A.1 than Condition I, With one Unit 1 and 2 4.16 kV shutdown board inoperable, the remaining Unit 1 and 2 4.16 kV shutdown boards are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition.

The overall reliability is reduced, however, because another single failure in the remaining three 4.16 kV shutdown boards could result in the minimum required ESF functions not being supported. Therefore, the 4.16 kV shutdown board must be restored to OPERABLE status within 5 days.

The 5 day time limit before requiring a unit shutdown in this Condition is acceptable because the remaining 4.16 kV shutdown boards have AC power available, and the probability of an event in conjunction with a single failure of a redundant component in the 4.16 kV shutdown board with AC power is low. (The redundant component is verified OPERABLE in accordance with Specification 5.5.11, Safety Function Determination Program (SFDP).)

(continued)

BFN-UNIT 1 B 3.8-89 Revision 0, 36 June 22, 2006

Distribution Systems - Operating B 3.8.7 BASES for reasons other ACTIONS A.2 than Condition I, (continued)

With a shutdown board inoperable, the associated DG would have no power distribution mechanism and would hence also be inoperable. Required actions for an inoperable DG are included in LCO 3.8.1.

for reasons other than Condition I, B.1 With one Unit 1 480 V shutdown board inoperable, the remaining 480 V shutdown board is capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition assuming no single failure. The overall reliability is reduced because a single failure in the remaining 480 V shutdown board could result in the minimum required ESF functions not being supported.

Therefore, the inoperable 480 V shutdown board must be restored to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This condition also bounds the inoperability of 480 V RMOV boards 1A or 1B.

The Condition B postulated worst case scenario is one division (480 V shutdown board) without AC power (i.e., no offsite power to the division and the associated DG inoperable). In this condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators' attention be focused on minimizing the potential for loss of power to the remaining division by stabilizing the unit, and on restoring power to the affected division. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time period before requiring a unit shutdown is acceptable because:

(continued)

BFN-UNIT 1 B 3.8-91 Revision 0

Distribution Systems - Operating B 3.8.7 BASES ACTIONS C.1 (continued)

The second Completion Time (12 days) for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable in any single contiguous occurrence of failing to meet the LCO. If Condition C is entered while, for instance, a 4.16 kV shutdown board is inoperable and subsequently restored OPERABLE, the LCO may already have been not met for up to 5 days. This situation could lead to a total duration of 10 days, since initial failure of the LCO, to restore the 480 V DG auxiliary board. At this time, a 4.16 kV shutdown board could again become inoperable, and the 480 V DG auxiliary board could be restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This allowance results in establishing the "time zero" at the time the LCO was initially not met, instead of at the time Condition C was entered. The 12 day Completion Time is an acceptable limitation on this potential of failing to meet the LCO indefinitely.

for reasons other D.1 than Condition I, With one Unit DC board or one Unit 1 and 2 Shutdown Board DC Distribution Panel inoperable, the remaining boards are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining boards could result in the minimum required ESF functions not being supported. Therefore, the required Unit DC board or Unit 1 and 2 Shutdown Board DC Distribution Panel must be restored to OPERABLE status within 7 days by powering it from the associated battery or charger. This condition also bounds the inoperability of 250 V RMOV boards 1A, 1B, or 1C.

(continued)

BFN-UNIT 1 B 3.8-95 Revision 0, 33 August 4, 2005

Distribution Systems - Operating B 3.8.7 BASES ACTIONS D.1 (continued)

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This allowance results in establishing the "time zero" at the time the LCO was initially not met, instead of at the time Condition D was entered. The 12 day Completion Time is an acceptable limitation on this potential of failing to meet the LCO indefinitely.

for reasons other E.1 than Condition I, With one division of 4.16 kV shutdown boards inoperable, the remaining division of shutdown boards is capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition assuming no single failure. The overall reliability is reduced because a single failure in the remaining 4.16 kV shutdown boards could result in the minimum required ESF functions not being supported.

Therefore, one of the inoperable 4.16 kV shutdown boards must be restored to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

The Condition E postulated worst case scenario is one division of 4.16 kV shutdown board without AC power (i.e., no offsite power to the division and the associated DGs inoperable). In this condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators' attention be focused on minimizing the potential for loss of power to the remaining division by stabilizing the unit, and on restoring power to the affected division. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time period before requiring a unit shutdown is acceptable because:

(continued)

BFN-UNIT 1 B 3.8-97 Revision 0, 33 August 4, 2005

Distribution Systems - Operating B 3.8.7 BASES ACTIONS E.1 (continued)

Pursuant to LCO 3.0.6, the Distribution System Actions B, C, or F would not be entered even if the 4.16 kV shutdown boards were inoperable, resulting in de-energization of a 480 V board.

Therefore, the Required Actions of Condition E are modified by a Note to indicate that when Condition E is entered with no AC source to the 4.16 kV shutdown boards, Actions B, C, or F must be immediately entered. This allows Condition E to provide requirement for the loss of the 4.16 kV shutdown boards without regard to whether 480 V board is de-energized. Actions B, C, or F provide the appropriate restrictions for a de-energized 480 V board.

, for reasons other than Condition I, F.1 Required Action F.1 is intended to provide assurance that a loss of one or more required Unit 2 or 3 AC or DC boards does not result in a complete loss of safety function of critical systems (i.e., SGT or CREVS). With one or more of the required boards inoperable, the SGT or CREVS train supported by each affected board is inoperable. Therefore, the associated SGT or CREVS subsystem must be declared inoperable immediately, and the ACTIONS in the appropriate system Specification taken.

(continued)

BFN-UNIT 1 B 3.8-99 Revision 0, 33 August 4, 2005

Distribution Systems - Operating B 3.8.7 BASES ACTIONS G.1 and G.2 (continued)

If the inoperable distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

for reasons other H.1 than Condition I, Condition H corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost. When more than one AC or DC electrical INSERT 1 power distribution subsystem is lost, and this results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the AC and DC electrical power distribution subsystem is functioning properly, with the buses energized. The verification of proper voltage availability on the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

BFN-UNIT 1 B 3.8-100 Revision 0, 33, 123 March 22, 2020

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FRPSHQVDWRU\DFWLRQVRI6HFWLRQRIWKHHQFORVXUHWR5HIHUHQFHDUHWDNHQDQGon a one-time basis for installation and testing RIthe Unit 3 Control Bay Chiller Cross-tie before October 1, 2025. This Condition, where two or more electrical power distribution subsystems are inoperable due to installation and testing of the Unit 3 Control Bay Chiller Cross-tie, provides 9 days to restore the affected electrical power distribution subsystems to OPERABLE status. In this Condition the equipment in the Unit 1 and Unit 2 electrical board rooms are considered not OPERABLE because chilled water will be isolated from the air handling units in those rooms. Without chilled water to those air handling units during a design basis accident, the temperature in the Unit 1 and Unit 2 electrical board rooms would eventually increase above design limits.

While not OPERABLE, the electrical power distribution subsystems are able to perform their safety function until the temperature in the Unit 1 and Unit 2 electrical board rooms exceed the design limits. At that point, the expected service life of equipment in those rooms are shortened by the increased temperatures. *LYHQWKHPRVWOLPLWLQJERDUGURRPUHDFKHVWKH

GHVLJQOLPLWWHPSHUDWXUHLQDSSUR[LPDWHO\KRXUVZLWKQRPLWLJDWLQJDFWLRQVWDNHQ, there is sufficient time during installation to restore the chilled water to the Unit 1 and Unit 2 electrical board room air handling units to prevent the temperature in the Unit 1 and Unit 2 electrical board rooms from reaching the design limits. Likewise, during testing and flow balancing of Unit 3 Control Bay Chiller Cross-tie, there is ample time to restore 8QLWchilled water to the Unit 1 and Unit 2 electrical board room air handling units to prevent temperatures in the Unit 1 and Unit 2 electrical board rooms from reaching design limits.

Compensatory measures listed in TVA letter CNL-21-020 will be taken during installation and testing to reduce the risk of plant transients and the loss of offsite power.

Distribution Systems - Operating B 3.8.7 BASES (continued)

REFERENCES 1. FSAR, Chapter 6.

2. FSAR, Chapter 14.
3. Regulatory Guide 1.93, December 1974.
4. NRC No.93-102, "Final Policy Statement on Technical Specification Improvements," July 23, 1993.
5. TVA Letter to NRC, CNL-21-020, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application Requesting NRC Prior Approval of a Proposed Chilled Water Crosstie Modification to Support System Operability, dated November 5, 2021 (ML21309A038)

BFN-UNIT 1 B 3.8-101 Revision 0

Attachment 2 Proposed Technical Specification Pages (Markups)

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Attachment 

3URSRVHG7HFKQLFDO6SHFLILFDWLRQ 3DJHV

5HW\SHG CNL-20

(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 &RQGLWLRQ,. C, and F when Condition A results in no power source to a required 480 volt board.

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 <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Shutdown Board OPERABLE status.

inoperable, for reasons AND other than &RQGLWLRQ,.

12 days from OR discovery of failure to meet LCO 480 V RMOV Board 1A inoperable, for reasons other than &RQGLWLRQ,.

OR 480 V RMOV Board 1B inoperable, for reasons other than &RQGLWLRQ,.

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 &RQGLWLRQ,. Distribution Panel to AND OPERABLE status.

OR 12 days from discovery of failure One Unit 1 and 2 Shutdown to meet LCO Board DC Distribution Panel inoperable, for reasons other than &RQGLWLRQ,.

OR 250 V DC RMOV Board 1A inoperable, for reasons other than &RQGLWLRQ,.

OR 250 V DC RMOV Board 1B inoperable, for reasons other than &RQGLWLRQ,.

OR 250 V DC RMOV Board 1C inoperable, for reasons other than &RQGLWLRQ,.

(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 &RQGLWLRQ,. C, and F when Condition E results in no power source to a OR required 480 volt board.

Unit 1 and 2 4.16 kV Shutdown Board C and D E.1 Restore one 4.16 kV 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable, for reasons Shutdown Board to other than &RQGLWLRQ,. OPERABLE status. AND 12 days from discovery of failure to meet LCO 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

&RQGLWLRQ,.

G. Required Action and G.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 of Condition A, B, AND C, D, E, or I not met.

G.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (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 Condition I..


NOTE--------------- I.1 Restore affected electrical 9 days Only applicable when the power distribution compensatory actions for subsystems to TVA letter CNL-21-020 are OPERABLE status.

taken and on a one-time basis for installation and testing of the Unit 3 Control Bay Chiller Cross-tie before October 1, 2025.

I. Two or more electrical power distribution subsystems inoperable due to installation and testing of the Unit 3 Control Bay Chiller Cross-tie.

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 &RQGLWLRQ-. C, D, and G when Condition A results in no power source to a required 480 volt board.

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 &RQGLWLRQ-. source to 480 volt RMOV board 2D or 2E.

OR --------------------------------------------

480 V RMOV Board 2A B.1 Restore Board to inoperable, for reasons OPERABLE status. 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> other than &RQGLWLRQ-.

AND OR 12 days from 480 V RMOV Board 2B discovery of inoperable, for reasons failure to meet other than &RQGLWLRQ-. LCO (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

&RQGLWLRQ-.

OR Unit 2 480 V RMOV Board 2E inoperable, for reasons other than

&RQGLWLRQ-.

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 &RQGLWLRQ-. Distribution Panel to AND OPERABLE status.

OR 12 days from discovery of One Unit 1 and 2 failure to meet Shutdown Board DC LCO Distribution Panel inoperable, for reasons other than &RQGLWLRQ-.

OR 250 V DC RMOV Board 2A inoperable, for reasons other than

&RQGLWLRQ-.

OR

9'&5029%RDUG

%LQRSHUDEOHIRU UHDVRQVRWKHUWKDQ

&RQGLWLRQ-

25

9'&5029%RDUG

&LQRSHUDEOHIRU UHDVRQVRWKHUWKDQ

&RQGLWLRQ-

(continued)

BFN-UNIT 2 3.8-36 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 &RQGLWLRQ-. and G when Condition F results in no power source to a required 480 volt OR board.

Unit 1 and 2 4.16 kV Shutdown Board C and D F.1 Restore one 4.16 kV 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable, for reasons other Shutdown Board to than &RQGLWLRQ-. OPERABLE status. AND 12 days from discovery of failure to meet LCO 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 &RQGLWLRQ-.

H. Required Action and H.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 of Condition A, B, D, E, F or J not AND met.

H.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 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 &RQGLWLRQ-.

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

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME


NOTE--------------- J.1 5HVWRUHDIIHFWHGHOHFWULFDO 9 days Only applicable ZKHQWKH SRZHUGLVWULEXWLRQ

FRPSHQVDWRU\DFWLRQVIRU VXEV\VWHPVWR23(5$%/(

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2FWREHU.

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&RQWURO%D\&KLOOHU

&URVVWLH

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 <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 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.

UHDVRQVRWKHUWKDQ

&RQGLWLRQ-

H. 5HTXLUHG$FWLRQDQG H.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 /> DVVRFLDWHG&RPSOHWLRQ

7LPHRI&RQGLWLRQ$% AND

'()RU-QRWPHW

H.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 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--------------- J.1 Restore affected electrical 9 days Only applicable when the power distribution compensatory actions for subsystems to OPERABLE TVA letter CNL-21-020 are status.

taken and on a one-time basis for installation and testing the Unit 3 Control Bay Chiller Cross-tie before October 1, 2025.

J. Two or more electrical power distributions subsystems inoperable due to installation of the Unit 3 Control Bay Chiller Cross-tie.

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