ML033381012

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Tech Spec Pages for Amendment No 286
ML033381012
Person / Time
Site: Browns Ferry Tennessee Valley Authority icon.png
Issue date: 12/01/2003
From:
Office of Nuclear Reactor Regulation
To:
Jabbour K, NRR/DLPM, 415-1496
Shared Package
ML033370762 List:
References
Download: ML033381012 (30)
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-:111,4 LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

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.

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, 286

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 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.

BFN-UNIT 2 3.0-5 Amendment No. 253, 286

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 KITrr-C

[Mt1 I I ---

------------------ - I-.n----------

1. Separate Condition entry is allowed for each Function.
2. 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. 243, 286

J-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 1 and 2.

ACTIONS

-------------------- - ------ NOTE-------------------_

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

BFN-UNIT 2 3.3-28 Amendment No. 2,37 286

RCS Leakage Detection Instrumentation 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required primary B.1 Analyze grab samples of Once per containment atmospheric primary containment 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> monitoring system atmosphere.

inoperable.

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

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

C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> D. All required leakage D.1 Enter LCO 3.0.3. Immediately detection systems inoperable.

BFN-UNIT 2 3.4-1 3 Amendment No. 2 53, 286

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 jiCilgm.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant specific --- ------- NOTE-------------

activity > 3.2 IiCi/gm and LCO 3.0.4.c is applicable. I

  • 26.0 liCi/gm DOSE -- --------

EQUIVALENT 1-131.

A.1 Determine DOSE Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> EQUIVALENT 1-131.

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

(continued)

BFN-UNIT 2 3.4-15 Amendment No. 253 286

rnr ;nutown o uooiing 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.
2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 or two required RHR A.1 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, 286

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 injection/spray 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 < 150 psig.

ACTIONS

-NOTE.

LCO 3.0.4.b is not applicable to HPCI.

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.

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

(continued)

BFN-UNIT 2 3.5-1 Amendment No. 253, 26 9 286

J ECCS - Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A not AND met.

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

BFN-UNIT 2 3.5-1 a Amendment No. 286 1

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.

ACTIONS K IPd fl

------------------------------ ----- I r------------------

LCO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System inoperable. A.1 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> dome pressure to

<150psig.

BFN-UNIT 2 3.5-1 2 Amendment No. 243 286

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 I and 2.

ACTIONS _

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

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

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met.

BFN-UNIT 2 3.6-40 Amendment No. 253,265, 286

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 1E AC Electrical Power Distributibn System;
b. Unit 1 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, and 3.

ACTIONS

- ---- - ------- -- - ----------------------- NI rOr - -- -------------- -

- -- IMI-J I r------ - ------- - --- - - -----

LCO 3.0.4.b is not applicable to DGs.

_~~~ --- __-- - - __-- -- - - -_ - - - -- - - -

CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite A.1 Verify power availability 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> circuit inoperable. from the remaining OPERABLE offsite AND transmission network.

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

BFN-UNIT 2 3.8-1 Amendment No. 263, 286

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.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

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. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.

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.

(continued)

BFN-UNIT 2 B 3.0-6 Amendment No. 286 Revision-0

LCO Applicability B 3.0 BASES LCO 3.0.4 The risk assessment may use quantitative, qualitative, or blended (continued) approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4(b), must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, 'Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions.

These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

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 (continued)

BFN-UNIT 2 B 3.0-7 Amendment No. 286 RePvio-o0

LCO Applicability B 3.0 BASES LCO 3.0.4 management actions. The LCO 3.0.4.b risk assessments do not (continued) have to be documented.

The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b 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.

(continued)

BFN-UNIT 2 B 3.0-8 Amendment No. 286 Revisier

LCO Applicability B 3.0 BASES LCO 3.0.4 The provisions of LCO 3.0.4 shall not prevent changes in MODES (continued) 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. Inthis 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.

(continued)

BFN-UNIT 2 B 3.0-8a Amendment No. 286

LCO Applicability B 3.0 BASES (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 in conflict 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 3.0-8b Amendment No. 286

SR Applicability SR Applicability B 3.0 BASES (continued)

SR 3.0.4 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.

(continued)

BFN-UNIT 2 B 3.0-17 Amendment No. 286 Revisione0

SR Applicability B 3.0 BASES SR 3.0.4 The provisions of SR 3.0.4 shall not prevent entry into MODES or (continued) 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 transitioning from MODE 1 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 I 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 I

discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

I BFN-UNIT 2 B 3.0-18 Amendment No. 286 RevisioGR

- I -

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 MODES I and 2. In MODES 3, 4, and 5, plant conditions are such that the likelihood of an event that would require PAM instrumentation is extremely low; therefore, PAM instrumentation is not required to be OPERABLE in these MODES.

ACTIONS Notes 1 and 2 have been provided to modify the ACTIONS related to PAM 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 compensatory measures for separate Functions. As such, Note 1 has been I provided to allow separate Condition entry for each inoperable PAM Function. Note 2 has been provided for Function 6 to I allow separate Condition entry for each penetration flow path.

(continued)

BFN-UNIT 2 B 3.3-92 Amendment No. 286 R6s1i4nO

Backup Control System B 3.3.3.2 BASES (continued)

ACTIONS A Note has been provided to modify the ACTIONS related to 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 allowvs 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.

I 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 Amendment No. 286 Pv isieoR4

a- . at RCS Leakage Detection Instrumentation B 3.4.5 BASES ACTIONS B.1 and B.2 (continued)

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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.

I C.l and C.2 If any 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to perform the actions in an orderly manner and without challenging plant systems.

D.1 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 Amendment No. 286 Revisie"

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 <26.0 pCi/rgm, samples must be analyzed for DOSE EQUIVALENT 1-131 at least once every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. In addition, the specific activity must be restored to the LCO limit within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The Completion Time of once every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is based on the time needed to take and analyze a sample. The 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 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.

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. This allowance is acceptable due to the significant conservatism incorporated 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 Amendment No. 286 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 2 B 3.4-45 Amendment No. 286

  • Revision 3

Jmw.t 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."

ACTIONS 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.

(continued)

BFN-UNIT 2 B 3.5-8 Amendment No. 269 286 Revision-0

ECCS - Operating B 3.5.1 BASES ACTIONS A.1 (continued)

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-;8a Amendment No. 286

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 < 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 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.

(continued)

BFN-UNIT 2 B 3.5-32 Amendment No. 286 Revision G

RCIC System B 3.5.3 BASES ACTIONS A.1 and A.2 (continued)

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 14 days. In this Condition, loss of the RCIC System will not affect the overall plant capability to provide makeup inventory at high reactor pressure since the HPCI System is the only high 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 3.5-32a Amendment No. 286

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. Inthis 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.

I 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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The alternate hydrogen control capabilities are provided by the Primary Containment Inerting System. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time (continued)

BFN-UNIT 2 B 3.6-93 Amendment No. 2IT&. 286 Revision-0

' l %/

AC Sources - Operating B 3.8.1 BASES (continued)

ACTIONS 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.

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 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 Amendment No. 286 Revision -

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