Text

Application to Revise Technical Specifications to Adopt TSTF-566-A, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, and TSTF-580-A, Revision 1, Provide Exception from Entering Mode 4
	ML23069A100
Person / Time
Site:	Browns Ferry
Issue date:	03/10/2023
From:	Hulvey K; Tennessee Valley Authority
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	CNL-22-045
	Download: ML23069A100 (1)
	v • d • e

TENNESSEE 1\14 VALLEY AUTHORITY 1101 Market Street, Chattanooga, Tennessee 37402 CNL-22-045 March 10, 2023 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Power 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 Revise Technical Specifications to Adopt TSTF-566-A, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, and TSTF-580-A, Revision 1, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling" (BFN TS-542)

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.90, Tennessee Valley Authority (TVA) is submitting a request for an amendment to the Technical Specifications (TS) for the Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3.

TVA requests adoption of Technical Specification Task Force (TSTF)-566-A, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems," and TSTF-580-A, Revision 1, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling which are approved changes to the Improved Standard Technical Specifications, into the BFN Units 1, 2, and 3 TS.

The proposed amendment revises the TS actions applicable when a residual heat removal (RHR) shutdown cooling subsystem is inoperable and provides a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable.

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed changes. Attachment 2 provides final retyped TS pages. Attachment 3 provides existing Unit 1 TS Bases pages marked to show the proposed changes (the BFN Unit 2 and 3 TS Bases are identical with respect to this change) and is provided for information only.

TVA requests that the amendment be reviewed under the Consolidated Line Item Improvement Process. Approval of the proposed amendment is requested within six months of completion of the Nuclear Regulatory Commission (NRC) acceptance review. Once approved, the amendment shall be implemented within 60 days.

U.S. Nuclear Regulatory Commission CNL-22-045 Page 2 March 10, 2023 There are no new regulatory commitments made in this submittal.

In accordance with 10 CFR 50.91(b)(1), a copy of this application, with attachments is being provided to the Alabama Department of Public Health.

If you should have any questions regarding this submittal, please contact Stuart L. Rymer at slrymer@tva.gov.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 10th day of March 2023.

Respectfully, Digitally signed by Edmondson, Carla Date: 2023.03.10 12:14:59 -05'00' Kimberly D. Hulvey Director, Nuclear Regulatory Affairs

Enclosure:

Description and Assessment cc: (with 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 Description and Assessment

Subject:

Browns Ferry Nuclear Plant, Units 1, 2, and 3, Application to Revise Technical Specifications to Adopt TSTF-566-A, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, and TSTF-580-A, Revision 1, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling" (BFN TS-542)

Table of Contents 1.0 DESCRIPTION................................................................................................................... 2

2.0 ASSESSMENT................................................................................................................... 2

2.1 Applicability of Safety Evaluation .................................................................................... 2

2.2 Variations ........................................................................................................................ 2

3.0 REGULATORY ANALYSIS ................................................................................................ 3

3.1 No Significant Hazards Consideration Determination .................................................... 3

3.2 Conclusion ...................................................................................................................... 4

4.0 ENVIRONMENTAL CONSIDERATION ............................................................................. 5

ATTACHMENTS

1. Proposed TS Changes (Mark-Ups) for BFN Units 1, 2, and 3

2. Proposed TS Changes (Final Retyped) for BFN Units 1, 2, and 3

3. Proposed TS Bases Page Changes (Mark-Ups) for BFN Unit 1 (For Information Only)

CNL-22-045 E1 of 5

Enclosure

1.0 DESCRIPTION

TVA requests adoption of Technical Specification Task Force (TSTF)-566-A, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems," and TSTF-580-A, Revision 1, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling which are approved changes to the Improved Standard Technical Specifications into the Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3 Technical Specifications (TS). The proposed amendment revises the TS actions applicable when a residual heat removal (RHR) shutdown cooling subsystem is inoperable and provides a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation TVA has reviewed the safety evaluations for TSTF-566 and TSTF-580 provided to the TSTF in letters dated February 21, 2019 and July 11, 2021, respectively. This review included a review of the Nuclear Regulatory Commission (NRC) staffs evaluation, as well as the information provided in TSTF-566-A and TSTF-580-A, Revision 1. As described herein, TVA has concluded that the justifications presented in TSTF-566-A and TSTF-580-A, Revision 1, and the safety evaluations 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 TS.

2.2 Variations TSTF-566-A revises the Actions for TS 3.4.8, "RHR Shutdown Cooling System - Hot Shutdown." TSTF-580-A makes further changes to the Actions of TS 3.4.8 that were revised by TSTF-566-A, which is consistent with the staff's approval of TSTF-580-A. The TSTF-580-A justification states that adoption is dependent on previous adoption of TSTF-566-A, which is satisfied by adopting both travelers.

The BFN TS utilize different numbering from the Standard Technical Specifications on which TSTF-566-A and TSTF-580-A, Revision 1 were based. The following table lists the differences.

These differences are administrative and do not affect the applicability of TSTF-566-A and TSTF-580-A, Revision 1 to the BFN TS.

TSTF-566-A and Title BFN TS Title TSTF-580-A TS TS 3.4.8 RHR Shutdown Cooling TS 3.4.7 RHR Shutdown Cooling System - Hot Shutdown System - Hot Shutdown TS 3.4.9 RHR Shutdown Cooling TS 3.4.8 RHR Shutdown Cooling System - Cold Shutdown System - Cold Shutdown TS B 3.9.8 RHR - High Water Level TS B 3.9.7 RHR - High Water Level TS B 3.9.9 RHR - Low Water Level TS B 3.9.8 RHR - Low Water Level Also, TSTF-580-A, Revision 1 describes two Residual Heat Removal Service Water (RHRSW) subsystems that are required to be Operable per NUREG-1433 TS 3.7.1, and that having both RHRSW subsystems inoperable drives a shutdown Required Action if one subsystem cannot be CNL-22-045 E2 of 5

Enclosure restored in 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . BFN TS 3.7.1 requires four RHRSW subsystems to be Operable per TS 3.7.1 and having three or more RHRSW subsystems inoperable drives a shutdown Required Action if one subsystem cannot be restored in 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The distinction is that the NUREG-1433 reference plant has two separate RHRSW subsystems for each unit. BFN has a shared RHRSW of four subsystems between the three units. However, this site-specific difference is irrelevant to the TSTF-580-A requirement that at least one RHR shutdown cooling subsystem be Operable before a required unit entry into Mode 4.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination TVA requests adoption of TSTF-566-A, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems," and TSTF-580-A, Revision 1, Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling, which are approved changes to the Improved Standard Technical Specifications into the BFN Unit 1, 2, and 3 TS. The proposed amendment revises the TS actions applicable when an RHR shutdown cooling subsystem is inoperable and provides a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable.

TVA has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 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 consequence of an accident previously evaluated?

Response: No.

The proposed change revises the actions to be taken when a RHR shutdown cooling subsystem is inoperable. The RHR System in the shutdown cooling mode performs the important safety function of removing decay heat from the reactor coolant system during shutdown. The RHR System in the shutdown cooling mode is not an initiator of any accident previously evaluated or assumed to mitigate any accident previously evaluated.

The design and function of the RHR System are not affected by the proposed change.

The proposed change would also exempt entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable and other operating modes of the RHR System are inoperable, such as Low Pressure Core Injection and RHR suppression pool cooling, and three or more subsystems of the support system for the RHR System heat exchangers, the RHRSW System, are inoperable. The TS for those RHR operating modes require entering Mode 4 when both required subsystems are inoperable. The TS for the RHRSW System require entering Mode 4 when three or more required subsystems are inoperable. Those operating modes and systems are not initiators to any accident previously evaluated but are used to mitigate the consequences of an accident previously evaluated. However, the consequences of an accident previously evaluated resulting from remaining in Mode 3 versus Mode 4 when RHR shutdown cooling subsystems are inoperable are not significantly increased because there would be no dependable method to remove post-accident decay heat in Mode 4 if both required RHR shutdown cooling subsystems are inoperable.

CNL-22-045 E3 of 5

Enclosure 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 accident previously evaluated?

Response: No.

The proposed change revises the actions to be taken when a RHR shutdown cooling subsystem is inoperable. The proposed change also provides a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable.

The proposed change does not affect the design function or operation of the RHR shutdown cooling subsystems. No new equipment is being installed as a result of the proposed change. The proposed change only affects the actions taken when one or both RHR shutdown cooling subsystems are inoperable, so no new failure mechanisms are created.

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

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

Response: No.

The proposed change revises the actions to be taken when a RHR shutdown cooling subsystem is inoperable and provides a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable. The proposed change does not change any specific values or controlling parameters that define margin in the design or licensing basis. No safety limits are affected by the proposed change. The RHR System in the shutdown cooling mode removes decay heat from the reactor coolant system during shutdown. The proposed change does not affect any design or safety limits associated with the RHR System. The proposed change also applies when both required RHR shutdown cooling subsystems are inoperable, so no design or safety limits associated with the operation of the RHR System are affected.

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

Based on the above, TVA concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

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 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.

CNL-22-045 E4 of 5

Enclosure

4.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

CNL-22-045 E5 of 5

Attachment 1 Proposed TS Changes (Mark-Ups) for BFN Units 1, 2, and 3 (12 pages)

CNL-22-045

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

*--- ---NOTES-------*

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

--*-----------NOTE---

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One er--twe required RHR A:4 ktiaate aetieA to rest&Fe kffltleeltatefy shutdown cooling ~-stn1teewA subsystems inoperable. e~esystem(s) te 9-PERABY=-steki&.

,________.r (continued) u BFN-UNIT 1 3.4-18 Amendment No. 234, ~

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS

% Required Action and associated CONDITION 1 REQUIRED ACTION COMPLETION Completion Time of TIME Condition A not met.

& Two required A. (continued) A.2 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months RHR shutdown method of decay heat cooling subsystems removal is available fo.F inoperable.

eaehi~

' Required Action RH~§ and associated .S1:19&Ystem. AND Completion Time of Condition C not met. AN9 Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter A:3 Be in MODE 4.

No RHR shutdown Initiate action to restore cooling subsystem

one RHR shutdown oration. cooling subsystem or one recirculation pump to Immediately operation.

AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND

%1 Initiate action to restore RHR E shutdown cooling subsystem to Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months fr Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status. circulation by an alternate discove thereafter method. reactor

&1 Verify an alternate method of circulatio decay heaW removal is available for Immediately each inoperable RHR shutdown AND cooling subsystem.

Once per

-NOTE------------------ 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LCO 3.0.3 and all other LCO Required thereafter Actions requiring a MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

.3 Monitor reactor coolant Once per hour

---

D.1 Initiate action to restore one RHR temperature and shutdown cooling subsystem to pressure.

OPERABLE status.

BFN-UNIT 1 3.4-19 Amendment No. ~

u

.RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES----------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Suryeillances.

APPLICABILITY: MODE 4.

ACTIONS

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

Separate Con~ition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION

REQUIRED ACTION COMPLETION TIME A. One or two required _RHR A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months B. Required Action and shutdown cooling

method of decay heat associated Completion

subsystems inoperable. removal is available for AND Time of Condition A B.1 Initiate action to each inoperable required not met. restore RHR shutdown RHR shutdown cooling Once per cooling subsystem(s)

~

subsystem. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to OPERABLE status. thereafter

....... }.

~ (continued)

IImmediately I BFN-UNIT 1 3.4-21 Amendment No. ~

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION

~ TIME 8-. No RHR shutdown B.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in circulating by an alternate discovery of no operati_on. method. reactor coolant circulation AND AND Once per.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C

8.2 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT 1 3.4-22 Amendment No. 234

RHR Shutdown Cooling System - Hot Shutdown 3.4.7

v 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR low pressure permissive pressure.

u ACTIONS

- - - - - - - - - - - - - - N O T E -

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One er-two required RHR M IRfflate-aelieA-te FestGFe Immediately shutdown cooling FCquired RHR-shutdo'NA subsystems inoperable. eooling subsystemEs~ to OPERABLE status.

'***** -I

,_______.r (continued) u BFN-UNIT2 3.4-18 Amendment No. ~ ~

E2EÂJs³a¹Â+ypÂJ1/2¨gÂ 2ÂJs³aºÂ

"$Â B. Required Action and associated

',L5@=KÂ Completion Time of Condition A not met. ,@=-6L7@= F/DN7G/-Â',L7@=Â ,@:C90L7@=Â 1 M7:1Â C. Two required RHR shutdown cooling subsystems ' ÂZ-l'hb ) Oh zl3/4ÂQÂRh R-hÂ Â tµ Â inoperable. h-ubÂlÂch_3/4ÂvhR-Â D. Required Action h¸RÂ{©ÂR¸RlTWhÂm Â and associated hR[vÂzh RWhÂhµl hcÂ Completion Time of H3FÂ©tµ-b>>Â\zqÂ AND Condition C not met. 'W©¿°hÂ Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter

) Â *hÂ{Â;@./Â Â Âtµ <<Â

% >ÂH3FÂvµ-b1/4 % Â 8l-R-hÂS^-}Â+/-Âh+/- hÂ 8hd~Qh3/4Â ZzqÂ<<'X©¿<<-iÂ{ iÂH4IÂ<<wµ°b>>Â i R-l ZzrÂ¬µY©1/2©²iÂ ÂiÂ iZl ZµT-?Â³Â²Â

i¢U- Â Immediately

>ÂiZZµR-lÂµÂÂ

\.__J iS-? Â 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

%Â Pi ÂhR` ÂZRÂ Ât¶ m Â AND E Z Z³R²ÂXÂRÂV²iR²iÂ e©[¸i§ÂnÂÂ i°wbÂ £iR` ÂZRÂ Once per 24 B.1 Initiate action to restore RHR shutdown Z Z¶R²?Â hours thereafter cooling subsystem to OPERABLE status.

Immediately C.1 Verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.

A[iÂj Â

Ât¶ ©Â

NOTE------------------------------ ²xkjRoi¥Â LCO 3.0.3 and all other LCO Required Actions requiring a MODE change to MODE 4 may be

suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

<?Â£iR`ÂZR°Â B]iÂiÂx¶Â

²ijR* iÂUfÂ

¥i©©µ iÂ D.1 Initiate action to restore one RHR shutdown cooling subsystem to OPERABLE status.

!&Â (jfjÂ?Â#Â#

RHR Shutdown Cooling System - Cold Shutdown 3 .4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLI_CABILITY: MODE 4.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required RHR

A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

B. Required Action and shutdown cooling method of decay heat associated Completion subsystems inoperable. removal is available for AND Time of Condition A B.1 Initiate action to . each inoperable required not met. restore RHR shutdown RHR shutdown cooling Once per cooling subsystem(s)

~ to OPERABLE status. I\ subsystem. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

\. thereafter

~

f I (continued)

IImmediately I

BFN-UNIT2 3.4-21 Amendment No. ~

u

RHR Shutdown Cooling System - Cold Shutdown

. 3 .4.8 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME 8-. No RHR shutdown 8.1 Verify reactor coolant 1 hourfrom cooling subsystem in circulating by an alternate discovery of no operation. method. reactor coolant circulation AND AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C

8.2 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT2 3.4-22 Amendment No. ~

u

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4. 7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES--------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

______, - - - - - - - - N O T E - - - -

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One 8f-twe required RHR M IAttiate-eetioA to r-esteFe Immediately shutdown cooling reqtlireEI RHR shutaewn subsystems inoperable. eooliAO subsystem(stt&

OPERABLE status:

.. _..,\

(continued) >

BFN-UNIT3 3.4-18 Amendment No. 242, ~

RHR Shutdown Cooling System - Hot Shutdown

' 3.4.7 1

ACTIONS B. Required Action CONDITION REQUIRED ACTION COMPLETION and associated TIME Completion Time of Condition A not met.

A. (continued) Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months C. Two required method of decay heat RHR shutdown removal is available f0I:..

cooling subsystems 1-

~,..........a,--

eash inoper.bla required AND inoperable. RHR shutdown cooling subsystem. Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months D. Required Action thereafter and associated Completion Time of AN9 Condition C not met. A3 lie in MODE 4.

-8. No RHR shutdown Initiate action to restore Immediately cooling subsystem i one RHR shutdown o ration. cooling subsystem or one 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months recirculation pump to AND operation.

Once per 24 No hours 0 thereafter E Verify reactor coolant 1 hourfrom Immediately circulation by an alternate discovery of no B.1 Initiate action to restore RHR shutdown method. reactor coolant cooling subsystem to OPERABLE status.

circulation C.1 Verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.

Once per

NOTE--------------------------- 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LCO 3.0.3 and all other LCO Required thereafter Actions requiring a MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

-8.3 Monitor reactor coolant Once per hour temperature and D.1 Initiate action to restore one RHR pressure.

shutdown cooling subsystem to OPERABLE status.

BFN-UNIT 3 3.4-19 Amendment No.-2.12.

RHR Shutdown Cooling System - Cold Shutdown

3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS)

'-._.,I 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 4.

ACTIONS

:NOTE-------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A One or two required RHR A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat B. Required Action and associated Completion subsystems inoperable. removal is available for AND Time of Condition A B.1 Initiate action to each inoperable required not met. restore RHR shutdown RHR shutdown cooling Once per cooling subsystem(s) to OPERABLE status. \ subsystem. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

~' I\ , thereafter

~ ~

It,...

\

Immediately (continued)

BFN-UNIT3 3.4-21 Amendment No. 242

RHR Shutdown Cooling System - Cold Shutdown

'3.4.8 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME 8-. No RHR shutdown 8-.1 Verify reactor coolant 1 hourfrom cooling subsystem in circulating by an alternate discovery of no operation. method. reactor coolant circulation AND AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C .2 Monitor reactor coolant Once per hour temperature and pressure.

\._,;

BFN-UNIT3 3.4-22 Amendment No. -2.:t-2

Attachment 2 Proposed TS Changes (Final Retyped) for BFN Units 1, 2, and 3 (15 pages)

CNL-22-045

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required RHR A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat subsystem inoperable. removal is available.

AND Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter (continued)

BFN-UNIT 1 3.4-18 Amendment No. 234, 249, ___

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Initiate action to restore Immediately associated RHR shutdown cooling Completion Time of subsystem to OPERABLE Condition A not met. status.

C. Two required RHR C.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat subsystems removal is available for AND inoperable. each inoperable RHR shutdown cooling Once per 24 subsystem hours thereafter D. Required Action and -------------------NOTE----------------- Immediately associated LCO 3.0.3 and all other LCO Completion Time of Required Actions requiring a Condition C not met. MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

D.1 Initiate action to restore one RHR shutdown cooling subsystem to OPERABLE status.

(continued)

BFN-UNIT 1 3.4-19 Amendment No. 234, ___

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. No RHR shutdown E.1 Initiate action to restore Immediately cooling subsystem in one RHR shutdown operation. cooling subsystem or one recirculation pump to AND operation.

No recirculation pump in AND operation.

E.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from circulation by an alternate discovery of no method. reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND E.3 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT 1 3.4-19a Amendment No. 234, ___

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 4.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required RHR A.1 Verify an alternate method 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling of decay heat removal is subsystems inoperable. available for each AND inoperable required RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and B.1 Initiate action restore RHR Immediately associated Completion shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(continued)

BFN-UNIT 1 3.4-21 Amendment No. 234, ___

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in circulating by an alternate discovery of no operation. method. reactor coolant circulation AND AND No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT 1 3.4-22 Amendment No. 234, ___

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required RHR A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat subsystem inoperable. removal is available. AND Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter (continued)

BFN-UNIT 2 3.4-18 Amendment No. 253, 286, ___

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Initiate action to restore Immediately associated Completion RHR shutdown cooling Time of Condition A not subsystem to OPERABLE met. status.

C. Two required RHR C.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat subsystems inoperable. removal is available for each inoperable RHR AND shutdown cooling subsystem.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter D. Required Action and ------------------NOTE------------------ Immediately associated Completion LCO 3.0.3 and all other LCO Time of Condition C not Required Actions requiring a met. MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

D.1 Initiate action to restore one RHR shutdown cooling subsystem to OPERABLE status.

(continued)

BFN-UNIT 2 3.4-19 Amendment No. 253, ___

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. No RHR shutdown E.1 Initiate action to restore Immediately cooling subsystem in one RHR shutdown operation. cooling subsystem or one recirculation pump to AND operation.

No recirculation pump in AND operation.

E.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from circulation by an alternate discovery of no method. reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND E.3 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT 2 3.4-19a Amendment No. 253, ___

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 4.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required RHR A.1 Verify an alternate method 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling of decay heat removal is subsystems inoperable. available for each AND inoperable required RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and B.1 Initiate action to restore Immediately associated Completion RHR shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(continued)

BFN-UNIT 2 3.4-21 Amendment No. 253, ___

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in circulating by an alternate discovery of no operation. method. reactor coolant circulation AND AND No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT 2 3.4-22 Amendment No. 253, ___

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required RHR A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat subsystem inoperable. removal is available. AND Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter (continued)

BFN-UNIT 3 3.4-18 Amendment No. 212, 244, ___

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Initiate action to restore Immediately associated Completion RHR shutdown cooling Time of Condition A not subsystem to OPERABLE met. status.

C. Two required RHR C.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat subsystems inoperable. removal is available for AND each inoperable RHR shutdown cooling Once per 24 subsystem. hours thereafter D. Required Action and ------------------NOTE------------------ Immediately associated Completion

Time of Condition C not LCO 3.0.3 and all other LCO meW. Required Actions requiring a MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

D.1 Initiate action to restore one RHR shutdown cooling subsystem to OPERABLE status.

(continued)

BFN-UNIT 3 3.4-19 Amendment No. 212

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. No RHR shutdown E.1 Initiate action to restore Immediately cooling subsystem in one RHR shutdown operation. cooling subsystem or one recirculation pump to AND operation.

No recirculation pump in AND operation.

E.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from circulation by an alternate discovery of no method. reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND E.3 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT 3 3.4-19a Amendment No. 212, ___

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 4.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required RHR A.1 Verify an alternate method 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling of decay heat removal is subsystems inoperable. available for each AND inoperable required RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and B.1 Initiate action to restore Immediately associated Completion RHR shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(continued)

BFN-UNIT 3 3.4-21 Amendment No. 212, ___

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in circulating by an alternate discovery of no operation. method. reactor coolant circulation AND AND No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT 3 3.4-22 Amendment No. 212, ___

Attachment 3 Proposed TS Bases Page Changes (Mark-Ups) for BFN Unit 1 (For Information Only)

(15 pages)

CNL-22-045

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown BASES BACKGROUND Irradiated fuel in the shutdown reactor core generates heat during the decay of fission products and increases the temperature of the reactor coolant. This decay heat must be removed to reduce the temperature of the reactor coolant to

! 212°F. This decay heat removal is in preparation for performing refueling or maintenance operations, or for keeping the reactor in the Hot Shutdown condition.

The RHR System has two loops with each loop consisting of two motor driven pumps, two heat exchangers, and associated piping and valves. There are two RHR shutdown cooling subsystems per RHR System loop. Both loops have a common suction from the same recirculation loop. The four redundant, manually controlled shutdown cooling subsystems of the RHR System provide decay heat removal. Each pump discharges the reactor coolant, after circulation through the respective heat exchanger, to the reactor via the associated recirculation loop.

The RHR heat exchangers transfer heat to the RHR Service Water System. Any one of the four RHR shutdown cooling subsystems can provide the required decay heat removal function.

(continued)

BFN-UNIT 1 B 3.4-42 Revision 0

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 BASES (continued)

APPLICABLE Decay heat removal by operation of the RHR System in the SAFETY ANALYSES shutdown cooling mode is not required for mitigation of any event or accident evaluated in the safety analyses. Decay heat removal is, however, an important safety function that must be accomplished or core damage could result. The RHR Shutdown Cooling System meets Criterion 4 of the NRC Policy Statement (Ref. 1).

LCO Two RHR shutdown cooling subsystems are required to be OPERABLE, and when no recirculation pump is in operation, one RHR shutdown cooling subsystem must be in operation.

An OPERABLE RHR shutdown cooling subsystem consists of one OPERABLE RHR pump, one heat exchanger, one RHRSW pump capable of providing cooling to the heat exchanger, and the associated piping and valves. The subsystems have a common suction source and are allowed to have common discharge piping. Since the piping is a passive component that is assumed not to fail, it is allowed to be common to the subsystems. Each shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. In MODE 3, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy. Operation of one subsystem can maintain or reduce the reactor coolant temperature as required.

However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required.

(continued)

BFN-UNIT 1 B 3.4-43 Revision 0

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 BASES LCO Note 1 permits both required RHR shutdown cooling (continued) subsystems and recirculation pumps to not be in operation for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. Note 2 allows one required RHR shutdown cooling subsystem to be inoperable for performance of Surveillance tests. These tests may be on the affected RHR System or on some other plant system or component that necessitates placing the RHR System in an inoperable status during the performance. This is permitted because the core heat generation can be low enough and the heatup rate slow enough to allow some changes to the RHR subsystems or other operations requiring RHR flow interruption and loss of redundancy.

APPLICABILITY In MODE 3 with reactor steam dome pressure below the RHR low pressure permissive pressure (i.e., the actual pressure at which the interlock resets) the RHR Shutdown Cooling System must be OPERABLE and shall be operated in the shutdown cooling mode to remove decay heat to reduce or maintain coolant temperature. Otherwise, a recirculation pump is required to be in operation.

In MODES 1 and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the RHR low pressure permissive pressure, this LCO is not applicable. Operation of the RHR System in the shutdown cooling mode is not allowed above this pressure because the RCS pressure may exceed the design pressure of the shutdown cooling piping. Decay heat removal at reactor pressures greater than or equal to the RHR low pressure permissive pressure is typically accomplished by condensing the steam in the main condenser. Additionally, in MODE 2 below this pressure, the OPERABILITY requirements for the Emergency Core Cooling Systems (ECCS) (LCO 3.5.1, "ECCS - Operating") do not allow placing the RHR shutdown cooling subsystem into operation.

(continued)

BFN-UNIT 1 B 3.4-44 Revision 0

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 BASES APPLICABILITY The requirements for decay heat removal in MODES 4 and 5 (continued) are discussed in LCO 3.4.8, "Residual Heat Removal (RHR)

Shutdown Cooling System - Cold Shutdown"; LCO 3.9.7, "Residual Heat Removal (RHR) - High Water Level"; and LCO 3.9.8, "Residual Heat Removal (RHR) - Low Water Level."

ACTIONS A Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition.

Section 1.3, also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

(continued)

BFN-UNIT 1 B 3.4-45 Amendment No. 249 Revision 3 December 1, 2003

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 BASES ACTIONS A.1, A A.2, 2 and A A.33 (continued)

With one required RHR shutdown cooling subsystem inoperable for decay heat removal, the inoperable subsystem must be restored to OPERABLE status without delaydelay. In this condition condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal removal. The overall reliability is reduced, however, because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability. Therefore, an alternate method of decay heat removal must be provided.

With both required RHR shutdown cooling subsystems inoperable, inoperable an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability inoperability. This re-establishes backup decay heat removal capabilities, capabilities similar to the requirements of the LCO.

LCO The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities capabilities.

The required cooling capacity of the alternate method should be ensured by verifying (by calculation or demonstration) its sufficient to capability to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or B.1 contributing to, the alternate method capability. Alternate If the required alternate methods that can be used include (but are not limited to) the ,

method of decay heat Condensate/Main Steam (feed and bleed) Systems and the removal cannot be verified adjacent unit(s) RHR SDC pumps and heat exchangers within one hour, immediate available through the RHR cross tie.

action must be taken to restore the inoperable RHR However, However due to the potentially reduced d reliability of the shutdown cooling subsystem alternate methods of decay heat removal removal, it is also required to to OPERABLE status. The reduce the reactor coolant temperature to th the he point where Required Action will restore MODE 4 is entered entered.

, or an inoperable but redundant decay heat functional RHR shutdown removal paths. The cooling subsystem immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal. (continued)

BFN-UNIT 1 B 3.4-46 Revision 0

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 E

BASES ACTIONS B B.1, B B.2, and BB.3 (continued)

With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as permitted by LCO Note 1, reactor coolant circulation by the RHR shutdown cooling subsystem or recirculation pump must be restored without delay.

Until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation. Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This will provide assurance of continued temperature monitoring capability.

During the period when the reactor coolant is being circulated C.1 by an alternate method (other than by the required RHR shutdown cooling subsystem or recirculation pump), the reactor With both [required] RHR shutdown cooling subsystems inoperable, an alternate method of decay heat coolant temperature and pressure must be periodically removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem monitored to ensure proper function of the alternate method.

inoperability. This re-establishes backup decay heat removal capabilities, similar to the requirements of The once per hour Completion Time is deemed appropriate.

the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore, verification of the functional availability of these alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will provide assurance of continued heat removal capability.

The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability. Alternate methods that can be used include (but are not limited to) the Condensate/

Main Steam (feed and bleed) Systems, the adjacent unit(s) RHR SDC pumps and heat exchangers available through the RHR cross tie, or an inoperable but functional RHR shutdown cooling subsystem.

D.1 If the required alternate methods of decay heat removal cannot be verified within one hour, immediate action must be taken to restore at least one RHR shutdown cooling subsystem to OPERABLE status. The immediate Completion Time reflects the importance of restoring a method of heat removal.

Required Action D.1 is modified by a Note indicating that all required MODE changes to MODE 4 may be (continued) suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status. In this case, LCO 3.0.3 and other Required Actions directing entry into MODE 4 could force the unit into a less safe conditionBFN-UNIT 1 in which there may be no adequate meansB 3.4-47 Revision 0 to allow to remove decay heat. It is more appropriate the restoration of one of the RHR shutdown cooling subsystems before requiring entry into a condition in which that subsystem would be needed and exiting a condition where other sources of cooling are available. When at least one RHR subsystem is restored to OPERABLE status, the Completion Times of LCO 3.0.3 or other Required Actions resume at the point at which they were suspended.

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 BASES (continued)

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This Surveillance verifies that one RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This Surveillance is modified by a Note allowing sufficient time to align the RHR System for shutdown cooling operation after clearing the pressure interlock that isolates the system, or for placing a recirculation pump in operation. The Note takes exception to the requirements of the Surveillance being met (i.e., forced coolant circulation is not required for this initial 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months period), which also allows entry into the Applicability of this Specification in accordance with SR 3.0.4 since the Surveillance will not be "not met" at the time of entry into the Applicability.

REFERENCES 1. NRC No.93-102, "Final Policy Statement on Technical Specification Improvements," July 23, 1993.

BFN-UNIT 1 B 3.4-48 Revision 0, 123 March 22, 2020

RHR Shutdown Cooling System - Cold Shutdown B 3.4.8 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown BASES BACKGROUND Irradiated fuel in the shutdown reactor core generates heat during the decay of fission products and increases the temperature of the reactor coolant. This decay heat must be removed to maintain the temperature of the reactor coolant

! 212°F. This decay heat removal is in preparation for performing refueling or maintenance operations, or for keeping the reactor in the Cold Shutdown condition.

The RHR System has two loops with each loop consisting of two motor driven pumps, two heat exchangers, and associated piping and valves. There are two shutdown cooling subsystems per RHR System loop. Both loops have a common suction from the same recirculation loop. The four redundant, manually controlled shutdown cooling subsystems of the RHR System provide decay heat removal. Each pump discharges the reactor coolant, after circulation through the respective heat exchanger, to the reactor via the associated recirculation loop. The RHR heat exchangers transfer heat to the RHR Service Water System. Any one of the four RHR shutdown cooling subsystems can provide the required decay heat removal function.

(continued)

BFN-UNIT 1 B 3.4-49 Revision 0

RHR Shutdown Cooling System - Cold Shutdown B 3.4.8 BASES (continued)

APPLICABLE Decay heat removal by operation of the RHR System in the SAFETY ANALYSES shutdown cooling mode is not required for mitigation of any event or accident evaluated in the safety analyses. Decay heat removal is, however, an important safety function that must be accomplished or core damage could result. The RHR Shutdown Cooling System meets Criterion 4 of the NRC Policy Statement (Ref. 1).

LCO Two RHR shutdown cooling subsystems are required to be OPERABLE, and when no recirculation pump is in operation, one RHR shutdown cooling subsystem must be in operation.

An OPERABLE RHR shutdown cooling subsystem consists of one OPERABLE RHR pump, one heat exchanger, one RHRSW pump capable of providing cooling to the heat exchanger, and the associated piping and valves. The subsystems have a common suction source and are allowed to have common discharge piping. Since piping is a passive component that is assumed not to fail, it is allowed to be common to the subsystems. Each shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. In MODE 4, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy. Operation of one subsystem can maintain or reduce the reactor coolant temperature as required.

However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required.

(continued)

BFN-UNIT 1 B 3.4-50 Revision 0, 91 June 17, 2015

RHR Shutdown Cooling System - Cold Shutdown B 3.4.8 BASES LCO Note 1 permits both required RHR shutdown cooling (continued) subsystems and recirculation pumps to not be in operation for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. Note 2 allows one RHR shutdown cooling subsystem to be inoperable for performance of Surveillance tests. These tests may be on the affected RHR System or on some other plant system or component that necessitates placing the RHR System in an inoperable status during the performance. This is permitted because the core heat generation can be low enough and the heatup rate slow enough to allow some changes to the RHR subsystems or other operations requiring RHR flow interruption and loss of redundancy.

APPLICABILITY In MODE 4, the RHR Shutdown Cooling System must be OPERABLE and shall be operated in the shutdown cooling mode to remove decay heat to maintain coolant temperature below 212°F. Otherwise, a recirculation pump is required to be in operation.

In MODES 1 and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the RHR low pressure permissive pressure, this LCO is not applicable. Operation of the RHR System in the shutdown cooling mode is not allowed above this pressure because the RCS pressure may exceed the design pressure of the shutdown cooling piping. Decay heat removal at reactor pressures greater than or equal to the RHR low pressure permissive pressure is typically accomplished by condensing the steam in the main condenser. Additionally, in MODE 2 below this pressure, the OPERABILITY requirements for the Emergency Core Cooling Systems (ECCS) (LCO 3.5.1, "ECCS-Operating") do not allow placing the RHR shutdown cooling subsystem into operation.

(continued)

BFN-UNIT 1 B 3.4-51 Revision 0

RHR Shutdown Cooling System - Cold Shutdown B 3.4.8 BASES APPLICABILITY The requirements for decay heat removal in MODE 3 below the (continued) low pressure permissive pressure and in MODE 5 are discussed in LCO 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown"; LCO 3.9.7, "Residual Heat Removal (RHR) - High Water Level"; and LCO 3.9.8, "Residual Heat Removal (RHR) - Low Water Level."

ACTIONS A Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition.

Section 1.3, also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

A.1 With one of the two required RHR shutdown cooling subsystems inoperable, the remaining subsystem is capable of providing the required decay heat removal. However, the overall reliability is reduced. Therefore, an alternate method of decay heat removal must be provided. With both required RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem (continued)

BFN-UNIT 1 B 3.4-52 Revision 0

RHR Shutdown Cooling System - Cold Shutdown B 3.4.8 BASES ACTIONS A.1 (continued) inoperability. This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore, verification of the functional availability of these alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will provide assurance of continued heat removal capability.

sufficient The required cooling capacity of the alternate method should be ensured by verifying (by calculation or demonstration) its capability to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability. Alternate methods that can be used include (but are not limited to) the Condensate/Main Steam (feed and bleed) Systems.

A C B.1 and B B B.2 or an inoperable but functional RHR shutdown cooling subsystem B.1 With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as permitted by LCO Note 1, and If the required alternate until RHR or recirculation pump operation is re-established, an method(s) of decay heat alternate method of reactor coolant circulation must be placed removal cannot be into service. This will provide the necessary circulation for verified within one hour, monitoring coolant temperature and pressure. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months immediate action must be taken Completion Time is based on the coolant circulation function to restore the inoperable RHR and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for shutdown cooling subsystem(s) each occurrence involving a loss of coolant circulation.

to OPERABLE status. The Furthermore, verification of the functioning of the alternate Required Action will restore method must be reconfirmed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This redundant decay heat removal will provide assurance of continued temperature and pressure paths. The immediate Completion Time reflects the monitoring capability.

importance of maintaining the availability of two paths for heat removal.

(continued)

BFN-UNIT 1 B 3.4-53 Revision 0, 91 June 17, 2015

RHR Shutdown Cooling System - Cold Shutdown B 3.4.8 BASES ACTIONS B.1 and B.2 (continued)

During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR shutdown cooling subsystem or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method.

The once per hour Completion Time is deemed appropriate.

SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This Surveillance verifies that one required RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. NRC No.93-102, "Final Policy Statement on Technical Specification Improvements," July 23, 1993.

BFN-UNIT 1 B 3.4-54 Revision 0, 123 March 22, 2020

RHR-High Water Level B 3.9.7 BASES (continued)

APPLICABILITY One RHR shutdown cooling subsystem must be OPERABLE and in operation in MODE 5, with irradiated fuel in the reactor pressure vessel and with the water level ! 22 feet above the top of the RPV flange, to provide decay heat removal. RHR shutdown cooling subsystem requirements in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS). RHR Shutdown Cooling System requirements in MODE 5 with irradiated fuel in the reactor pressure vessel and with the water level < 22 ft above the RPV flange are given in LCO 3.9.8, "Residual Heat Removal (RHR) - Low Water Level."

ACTIONS A.1 With no RHR shutdown cooling subsystem OPERABLE, an alternate method of decay heat removal must be established within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In this condition, the volume of water above the RPV flange provides adequate capability to remove decay heat from the reactor core. However, the overall reliability is reduced because loss of water level could result in reduced decay heat removal capability. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore, verification of the functional availability of these alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will ensure continued heat removal capability.

Alternate decay heat removal methods are available to the operators for review and preplanning in the unit's Operating Procedures.~- For -example, example

-- this-may-include

-- the-use- of -

the Reactor Water Cleanup System.

System The method used to remove conditions. \

the decay heat should be the most prudent choice based on unit The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability. Alternate methods that can be used include (but are not limited to) the Reactor Water Cleanup System or an inoperable but functional RHR shutdown cooling subsystem.

(continued)

BFN-UNIT 1 B 3.9-28 Revision 0

RHR-Low Water Level B 3.9.8 BASES (continued)

APPLICABILITY Two RHR shutdown cooling subsystems are required to be OPERABLE, and one must be in operation in MODE 5, with irradiated fuel in the RPV and with the water level < 22 ft above the top of the RPV flange, to provide decay heat removal. RHR shutdown cooling subsystem requirements in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS). RHR Shutdown Cooling System requirements in MODE 5 with irradiated fuel in the RPV and with the water level

! 22 ft above the RPV flange are given in LCO 3.9.7, "Residual Heat Removal (RHR) - High Water Level."

ACTIONS A.1 With one of the two required RHR shutdown cooling subsystems inoperable, the remaining subsystem is capable of providing the required decay heat removal. However, the overall reliability is reduced. Therefore an alternate method of decay heat removal must be provided. With both required RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability. This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore, verification of the functional availability of this alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will ensure continued heat removal capability.

Alternate decay heat removal methods are available to the operators for review and preplanning in the unit's Operating Procedures. For example example, this may include the use of the Reactor Water Cleanup System.

System The method used to remove decay heat should be the most prudent choice based on unit conditions.

The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability. Alternate methods that can be used include (but are not limited to) the Reactor Water Cleanup System or an inoperable but(continued) functional RHR shutdown cooling subsystem.

BFN-UNIT 1 B 3.9-33 Revision 0

v t e Letter Sequence Request
EPID:L-2023-LLA-0035, (Approved, Closed)
Initiation Acceptance... Administration Questions Answers Results Approval Other: ML23257A123
MONTHYEAR2023-09-22 [Table View]

CNL-22-045, Application to Revise Technical Specifications to Adopt TSTF-566-A, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, and TSTF-580-A, Revision 1, Provide Exception from Entering Mode 4

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CNL-22-045, Application to Revise Technical Specifications to Adopt TSTF-566-A, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, and TSTF-580-A, Revision 1, Provide Exception from Entering Mode 4

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3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL CONSIDERATION

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