Text

Units 1, 2, & 3 - TS Change 410 - Mode Change Limitations Using Consolidated Line Item Improvement Process
	ML032320267
Person / Time
Site:	Browns Ferry
Issue date:	08/07/2003
From:	Abney T; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TVA-BFN-TS-410
	Download: ML032320267 (47)
	v • d • e

Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 August 7, 2003 TVA-BFN-TS-410 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop: OWFN P1-35 Washington, D.C. 20555-0001 Gentlemen:

In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority : 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 - TECHNICAL SPECIFICATIONS (TS) CHANGE 410 - MODE CHANGE LIMITATIONS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)

Pursuant to 10 CFR 50.90,-the Tennessee Valley Authority-(TVA) is submitting a request for a TS change (TS-410)-to licenses DPR-33, DPR-52, and DPR-68-for BFN Units 1, 2,-and 3, respectively. The proposed amendment would modify TS requirements for mode change limitations in Limiting Condition for Operation 3.0.4 and Surveillance Requirement-3.0.4 to adopt the provisions of Industry/Technical Specification-Task Force (TSTF) change TSTF-359, "Increase Flexibility in Mode Restraints."

Enclosure 1 provides a description of the proposed change including a listing of-the affected TS with a brief description of the change, the confirmation 6f-'applicability, and the plant-specific verification. Enclosure 2 provides the existing Unit -2 TS-pages marked-up to show the proposed changes.

Identical changes are being requested for BFN Units 1 and 3 TS.

Enclosure 3 provides the existing Unit 2 TS Bases pages marked-up to show the proposed changes. Identical changes to the Units 1 and 3 TS Bases are proposed.

_"nte~d edeo

U.S. Nuclear Regulatory Commission Page 2 August 7, 2003 TVA is asking that this TS change be approved by December 1, 2003, and that the implementation of the revised TS be made within 60 days of NRC approval. The enclosed changes to the TS Bases will be implemented concurrently with the TS change in accordance with the TS Bases Control Program.

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

There are no regulatory commitments associated with this submittal. This letter is being sent in accordance with NRC Regulatory Issue Summary 2001-05, Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-ROM. If you have any questions about this TS change, please contact me at (256)729-2636.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August 7, 2003.

Manager an P dustry Affc irs Enc es:

1. Descrip Assessment

2. Proposed Technical Specifications Changes (mark-up)

3. Changes to Technical Specifications Bases Pages (mark-up) cc: (Enclosures)

State Health Officer Alabama State Department of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, Alabama 36130-3017

Enclosure 1 Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Technical Specifications (TS) Change 410 Mode Change Limitations Using the Consolidated Line Item Improvement Process (CLIIP)

Description and Assessment

1.0 DESCRIPTION

The proposed amendment would modify Technical Specifications (TS) requirements for mode change limitations in Limiting Condition for Operation (LCO) 3.0.4 and Surveillance Requirement (SR) 3.0.4. The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard TS (STS) change TSTF-359 Revision 8, as modified by the notice in the Federal Register published on April 4, 2003.

That Federal Register Notice (FRN) announced the availability of this TS improvement through the CLIIP.

TSTF-359 Revision 8 was subsequently revised to incorporate the modifications discussed in the April 4, 2003, FRN and other minor changes, and was submitted to NRC on April 28, 2003, as TSTF-359 Revision 9.

A description of the proposed TS/TS Bases changes that directly adopt TSTF-359 Revision 9 with no variations is provided directly below. A description of the TS/TS Bases changes where variances are required to adopt TSTF-359 Revision 9, due to differences between BFN TS and STS, is provided in Section 2.2 of this enclosure.

A. LCO 3.0.4 is revised to allow entry into a MODE or other specified condition in the Applicability while relying on the associated ACTIONS, provided that there is a risk assessment performed which justifies the use of LCO 3.0.4, the ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time, or an NRC approved allowance is provided in the Specification to be entered. The associated Bases are likewise being modified in accordance with TSTF-359 Revision 9. The

bracketed provisions in the Revision 9 Bases mark-ups have been removed for consistency with NUREG-1433 Revision 2, Standard Technical Specifications, "General Electric Plants, BWR/4."

B. SR 3.0.4 is revised to reflect the concepts of the change to LCO 3.0.4. The applicability of LCO 3.0.4 and SR 3.0.4-is expanded to include transition into all MODES or other specified conditions in the Applicability, except when required to comply with ACTIONS or that are part of a shutdown of the unit. The associated Bases are likewise being modified in accordance with TSTF-359 Revision 9. The bracketed provisions in the Revision 9 Bases mark-ups have been removed for consistency with NUREG-1433 Revision 2, Standard Technical Specifications, "General Electric Plants, BWR/4."

C. In LCO 3.5.1, Emergency Core Cooling System - Operating, an ACTIONS Note is added to indicate that the new LCO 3.0.4.b provision is not applicable to the High Pressure Coolant Injection system.

D. In LCO 3.5.3, Reactor Core Isolation Cooling, an ACTIONS Note is added to indicate that the new LCO 3.0.4.b provision is not applicable.

E. In LCO 3.8.1, Alternating Current - Operating, an ACTIONS Note is added to indicate that the new LCO 3.0.4.b provision is not applicable to diesel generators (DGs). provides the existing Unit 2 TS pages marked-up to show the proposed change. Identical changes are being requested for BFN Units 1 and 3 TS. Enclosure 3 provides the existing Unit 2 TS Bases pages marked-up to show the proposed change. Identical changes to the Units 1 and 3 TS Bases are proposed. LCO 3.0.4 and SR 3.0.4 are identical for all 3 BFN units.

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation The Tennessee Valley Authority (TVA) has reviewed the NRC safety evaluation dated March 28, 2003, as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-359 Revision 8 and included the consideration of the updates made in TSTF-359 Revision 9.

TVA has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC E1-2

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 Optional Changes and Variations TVA is not proposing any variations or deviations from the model TS/TS Bases changes for LCO 3.0.4 and SR 3.0.4 described in the modified TSTF-359 Revision 8 (as updated by Revision 9) and the NRC staff's model safety evaluation dated March 28, 2003.

However, due to minor differences between BFN TS/TS Bases and the model STS in NUREG-1433 Revision 2, Standard Technical Specifications, "General Electric Plants, BWR/4",

in several cases small variances from the TSTF mark-up changes are necessary. These variations are discussed below and do not affect the adoption or application of TSTF-359 Revision 9. All other TS Sections are modified without variance as described in Section 1.0 above. There are several minor technical differences among the 3 units for the affected LCO sections (setpoints, surveillance frequency, etc.). These technical differences do not affect the application of TSTF-359 Revision 9, so the same changes shown in Unit 2 TS/TS Bases mark-ups apply identically to the Units 1 and 3 TS/TS Bases.

A. BFN LCO 3.3.3.1, Post Accident Monitoring (PAM)

Instrumentation, is revised to delete Note 1 from the ACTIONS, which is the LCO 3.0.4 non-applicability Note, in accordance with the TSTF. BFN TS currently have a third Note under the LCO ACTIONS, whereas STS has only two notes. The retention of the third note (renumbered as Note 2) shows in Enclosures 2 and 3 as a deviation from the TSTF-359 Revision 9 mark-ups.

B. In the TSTF mark-ups, STS 3.3.3.2, Remote Shutdown System, Note 1 from the ACTIONS, which is the LCO 3.0.4 non-applicability Note, is deleted. The equivalent BFN TS is titled as TS 3.3.3.2, Backup Control System, and the same change is made.

C. In the TSTF mark-ups, STS 3.3.6.3, Low-Low Set (LLS)

Instrumentation, is modified. BFN TS do not have an equivalent section, so no changes are needed.

D. In the TSTF mark-ups, in STS 3.4.6, Reactor Coolant System (RCS) Leakage Detection Instrumentation, Note 1 from the ACTIONS, which is the LCO 3.0.4 non-applicability Note, is deleted. In BFN TS, the E1-3

equivalent TS is TS 3.4.5 (same title) and the LCO 3.0.4 non-applicability Note, which is being deleted, is located in REQUIRED ACTION B rather than the ACTIONS.

E. In the TSTF mark-ups, STS 3.4.7, Reactor Coolant System Specific Activity, a Note permitting the use of the new LCO 3.0.4.c provision is substituted for the existing LCO 3.0.4 non-applicability note in REQUIRED ACTION A.

In BFN TS, the equivalent TS is TS 3.4.6 (same title) and the same change is made.

F. In the TSTF mark-ups, STS 3.4.8, Residual Heat Removal (RHR) System - Hot Shutdown, Note 1 from the ACTIONS, which is the LCO 3.0.4 non-applicability Note, is deleted. In BFN TS, the equivalent TS is TS 3.4.7 (same title) and the same change is made.

G. In the TSTF mark-ups, STS 3.6.3.1, Primary Containment Hydrogen Recombiners, is modified. BFN TS do not have an equivalent section, so no changes are needed.

H. In the TSTF mark-ups, STS 3.6.3.2, Drywell Cooling System Fans, is modified. BFN TS do not have an equivalent section, so no changes are needed.

I. In the TSTF mark-ups, STS 3.6.3.4, Containment Atmospheric Dilution (CAD) System, the Note in REQUIRED ACTION A.1, which is the LCO 3.0.4 non-applicability Note, is deleted. In BFN TS, the equivalent TS is TS 3.6.3.1 (same title) and the same change is being made.

J. In the TSTF mark-ups, the LCO 3.0.4 non-applicability Note is being deleted from Required Action A for STS 3.7.3, Diesel Generator (DG) [iB] Standby Service Water (SSW) System. BFN TS do not have the direct equivalent of STS 3.7.3. A similar function (DG cooling) is provided by the Emergency Equipment Cooling Water (EECW)

System, which is addressed in BFN TS 3.7.2, EECW System and Ultimate Heat Sink. TS 3.7.2, however, does not have an LCO 3.0.4 non-applicability provision, so no changes are needed for consistency with TSTF-359.

3.0 REGULATORY ANALYSIS

3.1 No Significant Eazards Consideration Determination TVA has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. TVA has concluded that the proposed NSHCD presented in the Federal Register notice is E1-4

applicable to Browng Ferry Nuclear Plant and is, hereby, incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on April 4, 2003, for this TS improvement, plant-specific verifications were performed as follows:

TVA has established TS Bases for LCO 3.0.4 and SR 3.0.4, which state that use of the TS mode change limitation flexibility established by LCO 3.0.4 and SR 3.0.4 is not to be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to operable status before entering an associated mode or other specified condition in the TS Applicability.

The modification also includes changes to the Bases for LCO 3.0.4 and SR 3.0.4 that provide details on how to implement the new requirements. The Bases changes provide guidance for changing Modes or other specified conditions in the Applicability when an LCO is not met. The Bases changes describe in detail how: LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable

,systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; and LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification, which is typically applied to Specifications which describe values and parameters (e.g., Reactor Coolant System Activity), though it may be applied to other Specifications based on NRC plant-specific approval. The Bases also state that any risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants," and that the results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. Upon entry into a E1-5

MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the TS. The Bases also state that SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

The revised TS Bases will be implemented concurrently with the TS change in accordance with the TS Bases Control Program as described in TS 5.5.10.

4.0 ENVIRONMENTAL EVALUATION TVA has reviewed the environmental evaluation included in the model safety evaluation dated March 28, 2003, as part of the CLIIP. TVA has concluded that the staff's findings presented in that evaluation are applicable to BFN and the evaluation is hereby incorporated by reference for this application.

E1-6

Enclosure 2 Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Technical Specifications (TS) Change 410 Mode Change Limitations Using the Consolidated Line Item Improvement Process (CLIIP)

Proposed Technical Specifications Changes (mark-up)

I LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

When an LCO 1 not met, entry into a MODE or other specified condition i e Applicability shall not be made except when the ass ated ACTIONS to entered permit con d oper on in the MODE or er specified condo in the AK~icability for an unliit d period of time. is Specifica n

^na I not prevent chares in MODES or er specified conditions in the Apicability that are quired to cornly with MACTIONS or that are a part of a sh ownOf it/

Excep ionstois Sp'c fication are stated in the individual Specifications.

LCX.4 is only ap ible for entry rIoa MODE other sp06ffied conditiof the ApplicabW(f' in MODES 2 and 32 LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely-to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO Is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)." If a loss of safety function is (continued)

BFN-UNIT 2 3.0-2 Amendment No. 253

INSERT I (LCO 3.0.4)

When an LCO Is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition In the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing Inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated In the individual Specifications, or

c. When an allowance is stated in the Individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions In the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

SR Applicability 3.0 3.0 SR APPLICABILITY SR 3.0.3 If the Surveillance is not performed within the delay period, the (continued) LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LC all not be ma unless the LCO's Surveillances have bee et within their §ified Frequency.

> provision shaJ n t g p,-ve~nt enr it DES or other spc conditions He p v e th re required to com with ACTION or that are DEoohr^2odtosplicability

.part of a shutdown of the unitd f SR3.04jsonl aplicleforentry inin-a MODE or ther specifi, i te I cndij0i cbiityinMOD129 1,2 ,anP'r BFN-UNIT 2 3.0-5 Amendment No. 253

INSERT 2 (SR 3.0.4)

Entry into a MODE or other specified condition In the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO Is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made In accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE.

APPLICABILITY: MODES I and 2.

ACTIONS

-- -- - ------ HM IOTIES (g) i'>\@~ Separate Condition entry is allowed for each Function.

For Function 6, Separate Condition entry is allowed for each penetration flow path.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required channel 30 days with one required channel to OPERABLE status.

inoperable.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A not Specification 5.6.6.

met.

(continued)

BFN-UNIT 2 3.3-24 Amendment No. 253

Backup Control System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Backup Control System LCO 3.3.3.2 The Backup Control System Functions shall be OPERABLE.

APPLICABILITY: MODES I and 2.

ACTIONS Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required Function 30 days Functions inoperable. to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met BFN-UNIT 2 3.3-28 Amendment No. 253

I RCS Leakage Detection Instrumentation 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required primary NOTE containment atmospheric LCO $4)1npfapplical. ,

monitoring system p Z inoperable.

B.I Analyze grab samples of Once per primary containment 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months atmosphere.

AND B.2 Restore required primary 30 days containment atmospheric monitoring system to OPERABLE status.

C. Required Action and C.: Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B AND not met. C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. All required leakage D.1 Enter LCO 3.0.3. Immediately detection systems inoperable.

BFN-UNIT 2 3.4-13 Amendment No. 253

RCS Specific Activity 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT 1-131 specific activity < 3.2 pCi/gm.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated.

ACTIONS I F CONDITION REQUIRED ACTION COMPLETION TIME A Reactor coolant specific activity > 3.2 pCi/gm and s 26.0 +/-CiCgm DOSE EQUIVALENT 1-131.

A1 Determine DOSE Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EQUIVALENT 1-131.

AND A.2 Restore DOSE 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months EQUIVALENT 1-131 to within limits.

.1 I (continued)

BFN-UNIT 2 3.4-1 5 Amendment No. 253

INSERT 7 (RCS SPECIFIC ACTIVITY)

NNOTE O T E-LCO 3.0.4.c is applicable.

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.

&I ^,ln &

IULl I rt%

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

NOTECI

LCO~U.O.

/ s not appliabfeZ 6 Searat Conition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required RHR A1 Initiate action to restore Immediately shutdown cooling required RHR shutdown subsystems inoperable. cooling subsystem(s) to OPERABLE status.

AND (continued)

BFN-UNIT 2 3.4-18 Amendment No. 253

I ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS - Operating LCO 3.5.1 Each ECCS injectiontspray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure s 150 psig.

ACTIONS S-,A I CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray subsystem ECCS injection/spray inoperable. subsystem(s) to OPERABLE status.

One low pressure coolant injection (LPCI) pump in both LPCI subsystems inoperable.

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

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

BFN-UNIT 2 3.5-1 Amendment No. 26T 269 March 12,2001

BWR4 INSERT I (LCO 3.5.1, ECCS - OPERATING)

-NOTE LCO 3.0.4.b is not applicable to HPCI.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.

CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System inoperable. A1 Verify by administrative Immediately means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System to 14 days OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months dome pressure to

150 psig.

BFN-UNIT 2 3.5-12 Amendment No. 253

BWR4 INSERT 2 (LCO 3.5.3, RCIC SYSTEM)

-- NOTE- --

LCO 3.0.4.b Is not applicable to RCIC.

I CAD System 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Containment Atmosphere Dilution (CAD) System LCO 3.6.3.1 Two CAD subsystems shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CAD subsystem A.1 NOTEI-inoperable. L Restore CAD subsystem 30 days to OPERABLE status.

B. Two CAD subsystems B.1 Verify by administrative 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. means that the hydrogen control function is AND maintained.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.2 Restore one CAD 7 days subsystem to OPERABLE status.

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

BFN-UNIT 2 3.6-40 Amendment No. 2637 265 May 24, 2000

AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class I E AC Electrical Power Distribution System;

b. Unit I and 2 diesel generators (DGs) with two divisions of 480 V load shed logic and common accident signal logic OPERABLE; and

c. Unit 3 DG(s) capable of supplying the Unit 3 4.16 kV shutdown board(s) required by LCO 3.8.7, "Distribution Systems -

Operating."

APPLICABILITY: MODES 1,2,and3. -wRL4 \WLet 3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite A.1 Verify power availability 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months circuit inoperable. from the remaining OPERABLE offsite AND transmission network.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND (continued)

BFN-UNIT 2 3.8-1 Amendment No. 253

BWR4 INSERT 3 (LCO 3.8.1, AC SOURCES - OPERATING)

-- NOTE LCO 3.0.4.b is not applicable to DGs.

Enclosure 3 Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Technical Specifications (TS) Change 410 Mode Change Limitations Using the Consolidated Line Item Improvement Process (CLIIP)

Changes to Technical Specifications Bases Pages (mark-up)

LCO Applicability B 3.0 BASES LCO 3.0.3 Therefore, this LCO can be applicable in any or all MODES. If the (continued) LCO and the Required Actions of LCO 3.7.6 are not met while in MODE 1, 2, or 3, there is,no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.6 of "Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

WM-Te h00 req~i-rements, if the Applicability were entered, would result in the unit being required to exit the Applicability desired to be entered to comply with the R iufred Actions.

Compli with Required ions that ,permit con ued operation of the nit for an unlimite eriod of time in a M E or other spefed condition pro es an acceptable le I of safety for itinued operation.'his is without rega o the status of e unit efore or after the ODE change. The ore, in such ca s, entry into a MODE or er specified condiVn in the Appli ility may be made in a rdance with the pr isions of the R uired Actions. lwprwisions of this Specification shod 0 ot be interprete s endorsing the fiueoexrsee good practice of restorin sstms or compor nts to OPERABLE stts before unit/

startup. - -- -/

(continued)

BFN-UNIT 2 B 3.0-6 Revision 0

Insert 3 (LCO 3.0.4 Bases) (Cont) allowance should be generally acceptable, as long as the risk Is assessed and managed as stated above. However, there Is a small subset of systems and components that have been determined to be more Important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b Is not applicable.

LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note In the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions In the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c Is typically applied to Specifications which describe values and parameters (e.g., Reactor Coolant System Specific Activity), and may be applied to other Specifications based on NRC plant-specific approval.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of LCO 3.0.4 shall not prevent changes In MODES or other specified conditions In the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes In MODES or other specified conditions In the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4.

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry Into the applicable Conditions and Required Actions until the Condition Is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.

Surveillances do not have to be performed on the associated Inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on Inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

LCO Applicability B 3.0 BASES LCO 3.0.4 The provisions of LCO,.0.4 shall not prevent changes in MODES (continued) or other specified ditions in the Applicability that are required to comply with AC NS. In addition, t!e provisions of LCO 3.0.4 shall not pre nt changes in MODP or other specified conditions in the Ap cability that result f any unit shutdown.

E_ tions to LCO 3.0. re stated in the individual Specifications.

the exceptions allontry into MODES or other s ecified conditions in the plicability when the associa ACTIONS to be entered do no rovide for continued operatig, Pfor an unlimited period of ti Exceptions may apply to e ACTIONS or to a spec quired Action of a Specifi n.

LCO 3.0.4 is only applicable wh entering MODE 3 from DE 4, MODE 2 from MODE 3 or 4, ODE I from MODE 2.

urthermore, LCO 3.0.4 is, plicable when enterin ny other pecified condition in th plicabllity only while erating in ODE 1, 2, or 3. Th equirements of LCO .4do not apply in ODES 4 and 5, on other specified co ons of the Applicability unless in MOD, 2, or 3) because th OTiONS of individual pecifications s iciently define the r edial measures to be aken. [In some cases (e.g., ..) the ACTIONS provide a ote that tates 'While this LCO is not rg, entry into a MODE qoyther pecified condition in the Applicability is not permitt§ed unless equired to comply with ACTIONS." This Note is a fequirement xplicitly precluding entry into a MODE or other specified condition fthe Applicability.]

(continued)

BFN-UNIT 2 B 3.0-7 Revision 0

LCO Applicability B3.0 BASES LCO 3.0.4 (continued)

LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service Inconflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance.

(continued)

BFN-UNIT 2 B 3.0-8 Revision 0

SR Applicability B3.0 BASES (continued)

SR 3.0.4 .eslishes the requirement that all applicable SRs must be met before entry into ODE or other specified condition in the Applicability.

This Specificat ensures that system a component OPERABIL requirements and va e limits are met before entry into1ODES entry or other specifi conditions in the Applicability ityrf~nt for wh these systems and nts ensure safe operation of the it.

e provisions of this cification should not be in reted as endorsing the failur a exercise the good practi of restoring systems or com ents to OPERABLE status fore entering an associated M Eor other specified condVn in the Applicability.

However nceain circumstances f g to meet an SR will not result' SR 3.0.4 restricting a MO change or other specified l condion change. When a sys , subsystem, division, cofnponent, device, or varia is inoperable or outside its specified limits, the associ ed SR(s) are not required tI performed, per SR 3.0.1 ich states that Surveilla s do not have to be performed n inoperable equipment en equipment is inoperable, SR 3;.4 does not apply to the a ated SR(s) since the require ent for the SR(s) to be pe rmed is removed.

Therefore, faili to perform the Surveilla (s)within the spe Ied Frequency does not result in an SR 3.0 restriction to chang l MODES or other specified condition f the Applicability However, since the LCO is not me n this instance, L 3.0.4 will govern any restrictions that may or may not) apply to ODE or (continued)

BFN-UNIT 2 B 3.0-17 Revision 0

INSERT 4 (SR 3.0.4 BASES)

SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry Into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

A provision is included to allow entry into a MODE or other specified condition In the Applicability when an LCO Is not met due to Surveillance not being met In accordance with LCO 3.0.4.

However, In certain circumstances, failing to meet an SR will not result In SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside Its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on Inoperable equipment. When equipment Is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed.

Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability.

However, since the LCO is not met In this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions In the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes In MODES or other specified conditions In the Applicability that result from any unit shutdown. In this context, a unit shutdown Is defined as a change in MODE or other specified condition In the Applicability associated with transitloning from MODE I to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified In the Frequency, In the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified In a Surveillance procedure require entry Into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have Its Frequency specified such that it Is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

SR Applicability B 3.0 BASES SR 3.0.4 The provisions of SR 3.0.4 shall not prevent changes in MODES or (continued) other specified conditions in the plicability that are required to comply with ACTIONS. In ad if n, the provisions of SR 3.0.4 shall not prevent changes in MP S or other specified conditions in the Applicability that reSu 4om any unit shutdown.

The precise re irements for performance o s are specified such that e ptions to SR 3.0.4 are no cessary. The specific time fra s and conditions necessa or meeting the SRs are specid in the Frequency, in thlurveillance, or both. This avws performance of Surve nces when the prerequisite ndition(s) specified in urveillance procedure reqre entry into the MODE or other sp ied condition in the Appr ility of the associated LCO p to the performance or co letion of a Surveillance. iurveillance that could no performed until after entering the 0 Applicability would ha its Frequency specified such that s not "due" until the spe c conditions needed are met. terately, the Surveillan ay be stated in the form of a Note s not required (to be me r performed) until a particular event, condition, or time ha een reached. Further discussion of the specific formats of S annotation is found in Section 1.4, Frequency.

SR 3.0.4 is only plicable when entering MODE 3 f MODE 4, MODE 2 from ODE 3 or 4, or MODE I from MO 2.

Furthermore, SR 3.0.4 is applicable when ent ng any other specified condition in the Applicability only Hile operating in MODE 1, 2, or 3. The requirements of 3.0.4 do not apply in MODES 4 and 5, or in other specifo nditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be i>taken./

BFN-UNIT 2 B 3.018 Revision 0

PAM Instrumentation B 3.3.3.1 BASES (continued)

APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1 and 2.

These variables are related to the diagnosis and preplanned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in RV'.)DMS I and 2. In MODES 3, 4, and 5, plant conditions are s..h that the likelihood of an event that would require PAM instaumentation is extremely low, therefore, PAM instrumentation is not required to be OPERABLE in these MODES.

ACTIONS Note 1 has been added to the ACTIONS to exclude the MODE change restrict of 100 3.0.4. ,his exception allows entry into the appable MODE whil elying on the ACTIOlS even thoughKe ACTIONS may entually require pi utdown.

Thi exception is acce le due to the pas function of the pstruments, the op tor's ability to dia se an accident using alternative inst ents and methods d the low probability of an event requiring these instruments.

NotefIi R )have been provided to modify the ACTIONS leaedto AM instrumentation channels. Section 1.3, Completion Times, specifies that 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 that 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 PAM instrumentation channels provide appropriate comr e measures for separate Functions. As such, Note as been provided to allow separate Condition entry for each inoperable PAM Function. Note as been provided for Function 6 to allow separate Condition ntry for each penetration flow path.

(continued)

BFN-UNIT 2 B 3.3-92 Revision 0

Backup Control System Backup Control System B 3.3.3.2 BASES (continued)

ACTIONS A Note is included that excludes the MODE change restriction of LCO 3 .4. This excepti n allows entry i to an applicabl MOD hile relying on ACTIONS #though the A:lONS may eve ly require ant shutdown. is xception is actable due to low probabili f an event

>7Notepas been provided to modify the ACTIONS related to

(.JI Backup Control System Functions. Section 1.3, Completion Times, specifies that 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 that 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 Backup Control System Functions provide appropriate compensatory measures for separate Functions. As such, a Note has been provided that allows separate Condition entry for each inoperable Backup Control System Function.

A.1-Condition A addresses the situation where one or more required Functions of the Backup Control System is inoperable.

This includes any instrument parameter Function listed in Table B 3.3.3.2-1, as well as the control and transfer switches.

The Required Action is to restore the Function to OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room.

(continued)

BFN-UNIT 2 B 3.3-102 Revision 4 April09, 1999

I RCS Leakage Detection Instrumentation B 3.4.5 BASES ACTIONS 6.1 and B.2 (continued)

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval provides periodic information that is adequate to detect LEAKAGE. The 30 day Completion Time for restoration recognizes that at least one other form of leakage detection is available.

Ie Requiprd Actions are modified by a Note that s to the proions of LCwhic.4 are not applicable. As a result, a MO9E cange is; Mewed when bod aeuan statusthe pln containmeoghmospheric MDitoring 12chours andMODE4thsleTs allowancejeprovided becau Completionstimestaren isavailable to meNtor RCS leakage.

C.1 and C.2

,Ifany Required Action and associated Completion Time of Condition A or B cannot be met, the plant 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to perform the actions in an orderly manner and without challenging plant systems.

DA With all required monitors inoperable, no required automatic means of monitoring LEAKAGE are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

(continued)

BFN-UNIT 2 B 3.4-34 Revision 0

I RCS Specific Activity B 3.4.6 BASES (continued)

APPLICABILITY In MODE 1, and MODES 2 and 3 with any main steam line not isolated, limits on the primary coolant radioactivity are applicable since there is an escape path for release of radioactive material from the primary coolant to the environment in the event of an MSLB outside of primary containment.

In MODES 2 and 3 with the main steam lines isolated, such limits do not apply since an escape path does not exist. In MODES 4 and 5, no limits are required since the reactor is not pressurized and the potential for leakage is reduced.

ACTIONS A.1 and A.2 When the reactor coolant specific activity exceeds the LCO DOSE EQUIVALENT 1-131 limit, but is s 26.0 j+/-Cilgm, samples must be analyzed for DOSE EQUIVALENT 1-131 at least once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Inaddition, the specific activity must be restored to the LCO limit within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The Completion Time of once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is based on the time needed to take and analyze a sample. The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time to restore the activity level provides a reasonable time for temporary coolant activity increases (iodine spikes) to be cleaned up with the normal processing systems.

shutdowna b due to the significant conservatism Rhcorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to power operation.

(continued)

BFN-UNIT 2 B 3.4-39 Revision 0

INSERT 8 (RCS SPECIFIC ACTMTY BASES)

A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry Into the applicable MODE(S) while relying on the ACTIONS.

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, I "Residual Heat Removal (RHR) - High Water Level"; and LCO 3.9.8, "Residual Heat Removal (RHR) - Low Water I Level."

ACTIONS A Note to the /~ excludes the MODE change restriction of LCO 3.0.4. exception al entry into the applicable MODE(S) v. relying on t ACTIONS ev ough the ACTION ay eventua require plant utdown. This excep n is accept due to the r undancy of the OPABLE sub tems, the lo ressure at w e plant is erating, the w probabili f an event o rng during operation i is conditioaand the availa ity of alternate methods of decay heat removal capability. -

A seeemd 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 2 B 3.4-45 Revision 3 March 19, 1999

ECCS - Operating B 3.5.1 BASES LCO LPCI subsystems may be considered OPERABLE during (continued) alignment and operation for decay heat removal when below the actual RHR low pressure permissive pressure in MODE 3, if capable of being manually realigned (remote or local) to the LPCI mode and not otherwise inoperable. At these low pressures and decay heat levels, a reduced complement of ECCS subsystems should provide the required core cooling, thereby allowing operation of RHR shutdown cooling when necessary.

APPLICABILITY All ECCS subsystems are required to be OPERABLE during MODES 1, 2, and 3, when there is considerable energy in the reactor core and core cooling would be required to prevent fuel damage in the event of a break in the primary system piping. In MODES 2 and 3, when reactor steam dome pressure is

< 150 psig, ADS and HPCI are not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below.this pressure. ECCS requirements for MODES 4 and 5 are specified In LCO 3.5.2, "ECCS -

Shutdown."

A.1 If any one low pressure ECCS injection/spray subsystem is Inoperable, or if one LPCI pump in both LPCI subsystems is inoperable, the inoperable subsystem(s) must be restored to OPERABLE status within 7 days. In this condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced, because a single failure in one of the remaining OPERABLE subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function.

(continued)

BFN-UNIT 2 B 3.5-8 Amendment No. 269 Revision O March 12, 2001

BWR4 INSERT IB (LCO 3.5.1, ECCS - OPERATING)

A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCI subsystem. There is an increased risk associated with entering a MODE or other specified condition In the Applicability with an inoperable HPCI subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition In the Applicability with the LCO not met after performance of a risk assessment addressing Inoperable systems and components, should not be applied in this circumstance.

RCIC System B 3.5.3 BASES (continued)

LCO The OPERABILITY of the RCIC System provides adequate core cooling such that actuation of any of the low pressure ECCS subsystems is not required in the event of RPV isolation accompanied by a loss of feedwater flow. The RCIC System has sufficient capacity for maintaining RPV inventory during an isolation event.

APPLICABILITY The RCIC System is required to be OPERABLE during MODE 1, and MODES 2 and 3 with reactor steam dome pressure > 150 psig, since RCIC is the primary non-ECCS water source for core cooling when the reactor is isolated and pressurized. In MODES 2 and 3 with reactor steam dome pressure s 150 psig, and in MODES 4 and 5, RCIC is not required to be OPERABLE since the low pressure ECCS injection/spray subsystems can provide sufficient flow to the RPV.

ACTIONS A1 and A.2 If the RCIC System is inoperable during MODE 1, or MODE 2 or 3 with reactor steam dome pressure > 150 psig, and the HPCI System is immediately verified to be OPERABLE, the RCIC System must be restored to OPERABLE status within 9> wt 4 14 days. In this Condition, loss of the RCIC System will not affect the overall plant capability to provide makeup inventory at

\ v s e

reactor pressure since the HPCI System is the only high t 6 bhigh pressure system assumed to function during a loss of coolant accident (LOCA). OPERABILITY of HPCI is therefore immediately verified when the RCIC System is inoperable. This may be performed as an administrative check, by examining logs or other information, to determine if HPCI is out of service for maintenance or other reasons. It does not mean it is (continued)

BFN-UNIT 2 B 3.5-32 Revision 0

BWR4 INSERT 2B (LCO 3.5.3, RCIC SYSTEM)

A Note prohibits the application of LCO 3.0.4.b to an Inoperable RCIC system. There Is an increased risk associated with entering a MODE or other specified condition in the Applicability with an Inoperable RCIC system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition In the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied In this circumstance.

CAD System B 3.6.3.1 BASES (continued)

ACTIONS A.1 If one CAD subsystem is inoperable, it must be restored to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CAD subsystem is adequate to perform the oxygen control function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced oxygen control capability. The 30 day Completion Time is based on the low probability of the occurrence of a LOCA that would generate hydrogen and oxygen in amounts capable of exceeding the flammability limit, the amount of time available after the event for operator action to prevent exceeding this limit, and the availability of the OPERABLE CAD subsystem and other hydrogen mitigating systems.

euired Action A.1 has been modified by a Note that indicate that the visions of LCO 3.0.4 are not applicable. As a result, a MO change is allow d when one CAD subsystem is ino rable. This allo ce is provided because of the low bability of the ogpurrence of a LOC at would generate hydrogen and o gen in amounts ble of exceeding flammability it, the low proba y of the failure of OPERAB subsystem, the ount of time ava e after a postul~ d LOCA for ope or action to prevg exceeding the flammability limit, and~t e presence of a1erted containment atmosphere during normal operations.

B.1 and B.2 With two CAD subsystems inoperable, the ability to control the hydrogen control function via alternate capabilities must be verified by administrative means within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The alternate hydrogen control capabilities are provided by the Primary Containment Inerting System. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time (continued)

BFN-UNIT 2 B 3.6-93 Amendment No. 265 Revision 0 May 24,2000

AC Sources - Operating B 3.8.1 BASES (continued)

ACTIONS A.1 To ensure a highly reliable power source remains with one required offsite circuit inoperable, it is necessary to verify the availability of the remaining required offsite circuit on a more ZW L A frequent basis. This action ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. If a second required circuit is not available, the second offsite circuit is inoperable, and Condition E, for two offsite circuits inoperable, is entered.

A.2 Required Action A.2, which only applies if one or both 4.16 kV shutdown boards in a division cannot be powered from a qualified offsite source, is intended to provide assurance that an event with a coincident single failure of a DG does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related divisions (i.e., single division systems are not included). Redundant required features failures consist of inoperable features associated with a division redundant to the division that has no offsite power. For example, if no qualified offsite power source was available to 4.16 kV shutdown board A and RHR pump D was inoperable for maintenance, then RHR pump A would have to be declared inoperable.

(continued)

BFN-UNIT 2 B 3.8-11 Revision 0

BWR4 INSERT 3B (LCO 3.8.1, AC SOURCES - OPERATING)

A Note prohibits the application of LCO 3.0.4.b to an Inoperable DG. There Is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry Into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing Inoperable systems and components, should not be applied in this circumstance.

ML032320267

Text

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

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