Text

Issuance of Amendment Nos. 311, 334, and 294 Adopt Technical Specifications Task Force Traveler, TSTF-542, Revision 2
	ML19294A011
Person / Time
Site:	Browns Ferry
Issue date:	12/26/2019
From:	Michael Wentzel; Plant Licensing Branch II
To:	Jim Barstow; Tennessee Valley Authority
	Wentzel, Michael
References
	EPID L-2019-LLA-0010
	Download: ML19294A011 (197)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 December 26, 2019 Mr. James Barstow Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A-C Chattanooga, TN 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 - ISSUANCE OF AMENDMENT NOS. 311, 334, AND 294 TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER, TSTF-542, REVISION 2, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" (EPID L-2019-LLA-0010)

Dear Mr. Barstow:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 311, 334, and 294 to Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant, Units 1, 2, and 3, respectively. The amendments consist of changes to the technical specifications to adopt Technical Specifications Task Force Traveler, TSTF-542, "Reactor Pressure Vessel Water Inventory Control," in response to your application dated January 25, 2019, as supplemented by letter dated August 8, 2019.

The amendments replace existing technical specification requirements related to "operations with the potential for draining the reactor vessel (OPDRVs)" with new requirements on reactor pressure vessel water inventory control to protect Safety Limit 2.1.1.3. Safety Limit 2.1.1.3 requires reactor vessel water level to be greater than the top of active irradiated fuel.

J. Barstow A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Michael J. Wentzel, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296

Enclosures:

1. Amendment No. 311 to DPR-33

2. Amendment No. 334 to DPR-52

3. Amendment No. 294 to DPR-68

4. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-259 BROWNS FERRY NUCLEAR PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 311 Renewed License No. DPR-33

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated January 25, 2019, as supplemented by letter dated August 8, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-33 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 311, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

Enclosure 1

3. This license amendment is effective as of its date of issuance, and because of shared-system complexity and to ensure uniform implementation across all three units, the amendments shall be implemented for all three units prior to the start of the interval beginning with the Browns Ferry Nuclear Plant, Unit 3, Spring 2022, Cycle 20, refueling outage (3U20).

rFOR THE NUCLEAR REGULATORY COMMISSION I;\L t~* /tfI ~ tI .___;(-/

I' I' LL, l\l L l ,) '

-..:;--_:::::..:--dndine S. Shoop, Chief , '

Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: December 26, 2019

ATIACHMENT TO LICENSE AMENDMENT NO. 311 BROWNS FERRY NUCLEAR PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-33 DOCKET NO. 50-259 Replace the following page of Renewed Facility Operating License No. DPR-33 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT 3 3 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT REMOVE INSERT 1.1-3 1.1-3 3.5-11 3.5-11 1.1-3a 3.5-12 3.5-12 3.3-36 3.3-36 3.6-9 3.6-9 3.3-37 3.3-37 3.6-10 3.6-10 3.3-38 3.3-38 3.6-13 3.6-13 3.3-42 3.3-42 3.6-44 3.6-44 3.3-43 3.3-43 3.6-45 3.6-45 3.3-44 3.3-44 3.6-47 3.6-47 3.3-47a 3.6-48 3.6-48 3.3-47b 3.6-49 3.6-49 3.3-47c 3.6-51 3.6-51 3.3-48 3.3-48 3.6-52 3.6-52 3.3-49 3.3-49 3.6-53 3.6-53 3.3-50 3.3-50 3.7-8 3.7-8 3.3-51 3.3-51 3.7-8a 3.3-56 3.3-56 3.7-9 3.7-9 3.3-60 3.3-60 3.7-10 3.7-10 3.3-64 3.3-64 3.7-12 3.7-12 3.3-69 3.3-69 3.7-14 3.7-14 3.5-1 3.5-1 3.8-16 3.8-16 3.5-8 3.5-8 3.8-18 3.8-18 3.5-9 3.5-9 3.8-27 3.8-27 3.5-10 3.5-10 3.8-40 3.8-40

(3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3952 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 311, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 234 to Facility Operating License DPR-33, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 234. For SRs that existed prior to Amendment 234, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 234.

BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 311

Definitions 1.1 1.1 Definitions (continued)

CORE OPERATING LIMITS The COLR is the unit specific document that provides REPORT (COLR) cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, 1-132, 1-133, 1-134, and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table Ill of TID-14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites."

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a. The water inventory above the TAF is divided by the limiting drain rate;

b. The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths; (continued)

BFN-UNIT 1 1.1-3 Amendment No.~. 3Q.4., 311

Definitions 1.1 1.1 Definitions (continued)

DRAIN TIME (continued) 2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation devices without offsite power.

c. The penetration flow paths required to be evaluated per paragraph b are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;

d. No additional draining events occur; and

e. Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

INSERVICE TESTING The INSERVICE TESTINGPROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

(continued)

BFN-UNIT 1 1.1-3a Amendment No. 234, 30+, 311

ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. As required by Required B.1 -----~-~--NOl"E------------

Action A.1 and referenced Only applicable for in Table 3.3.5.1-1. Functions 1.a, 1.b, 2.a, and 2.b.

Declare supported ECCS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from feature(s) inoperable discovery of loss when its redundant of initiation feature ECCS initiation capability for capability is inoperable. features in both divisions AND B.2 ----~-------NOl"E-~---------

Only applicable for Functions 3.a and 3.b.

Declare High Pressure 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from Coolant Injection (HPCI) discovery of loss System inoperable. of HPCI initiation capability AND B.3 Place channel in trip. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

BFN-UNll" 1 3.3-36 Amendment No.~. 311

ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. As required by Required C.1 ~----------NOTE------------

Action A.1 and referenced Only applicable for in Table 3.3.5.1-1. Functions 1.c, 1.e, 2.c, 2.d, and 2.f.

Declare supported ECCS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from feature(s) inoperable discovery of loss when its redundant of initiation feature ECCS initiation capability for capability is inoperable. features in both divisions AND C.2 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

D. As required by Required D.1 -------------NC>TE------------

Action A.1 and referenced Only applicable if HPCI in Table 3.3.5.1-1. pump suction is not aligned to the suppression pool.

Declare HPCI System 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable.

(continued)

BFN-UNIT 1 3.3-37 Amendment No.~. 311

ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. As required by Required E.1 ------------NOTE---------~

Action A.1 and referenced Only applicable for in Table 3.3.5.1-1. Function 1.d.

Declare supported ECCS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from feature(s) inoperable discovery of loss when its redundant of initiation feature ECCS initiation capability for capability is inoperable. subsystems in both divisions AND E.2 Restore channel to 7 days OPERABLE status.

(continued)

BFN-UNIT 1 3.3-38 Amendment No.~. 311

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 1 of6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED FUNCTION OR OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER REQUIRED REQUIREMENTS VALUE CONDITIONS FUNCTION ACTION A.1

1. Core Spray System

a. Reactor Vessel Water 1,2,3 ,1(b) B SR 3.3.5.1.1 ?: 398 inches Level - Low Low Low, SR 3.3.5.1.2 above vessel Level 1(e) SR 3.3.5.1.5 zero SR 3.3.5.1.6

b. Drywell Pressure

1,2,3 B SR 3.3.5.1.2 5 2.5 psig High(e) SR 3.3.5.1.5 SR 3.3.5.1.6

c. Reactor Steam Dome 1,2,3 4(b) C SR 3.3.5.1.2 ?: 435 psig Pressure - Low (Injection 2 per trip SR 3.3.5.1.4 and Permissive and ECCS system SR 3.3.5.1.6 $ 465 psig lnilialion)(e)

d. Core Spray Pump 1,2,3 2 E SR 3.3.5.1.2 ?: 1647gpm Discharge Flow

Low 1 per SR 3.3.5.1.5 and (Bypass) subsystem 5 2910gpm

e. Core Spray Pump Start

Time Delay Relay Pumps A,B,C,D (with 1,2,3 4 C SR 3.3.5.1.5 ?: 6 seconds diesel power) 1 per pump SR 3.3.5.1.6 and 5 8 seconds Pump A (with normal 1,2,3 C SR 3.3.5.1.5 ?: 0 seconds power) SR 3.3.5.1.6 and 5 1 second Pump B (with normal 1,2,3 C SR 3.3.5.1.5 ?: 6 seconds power) SR 3.3.5.1.6 and 5 8 seconds continued (a) Deleted.

(b) Channels affect Common Accident Signal Logic. Refer to LCO 3.8.1, "AC Sources - Operating."

(e) During instrument calibrations, if the As Found channel setpoinl is conservative with respect to the Allowable Value but outside its acceptable As Found band as defined by its associated Surveillance Requirement procedure, then there shall be an initial determination to ensure confidence that the channel can perform as required before returning the channel to service in accordance with the Surveillance. If the As Found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

Prior to returning a channel to service, the instrument channel setpoint shall be calibrated to a value that is within the acceptable As Left tolerance of the setpoint; otherwise, the channel shall be declared inoperable.

The nominal Trip Selpoinl shall be specified on design output documentation which is incorporated by reference in the Updated Final Safety Analysis Report. The methodology used to determine the nominal Trip Setpoint, the predefined As Found Tolerance, and the As Left Tolerance band, and a listing of the setpoint design output documentation shall be specified in Chapter 7 of the Updated Final Safety Analysis Report.

BFN-UNIT 1 3.3-42 Amendment No. 2-34, 251, 311

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 2 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED FUNCTION OR OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER REQUIRED REQUIREMENTS VALUE CONDITIONS FUNCTION ACTIONA.1

1. Core Spray System (continued)

e. Core Spray Pump Start -

Time Delay Relay (continued)

Pump C (with normal power) 1,2,3 C SR 3.3.5.1.5 2: 12 seconds SR 3.3.5.1.6 and s 16 seconds Pump D (with normal power) 1,2,3 C SR 3.3.5.1.5 2: 18 seconds SR 3.3.5.1.6 and s 24 seconds

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Vessel Water 1,2,3 4 B SR 3.3.5.1.1 2: 398 inches Level - Low Low Low, SR 3.3.5.1.2 above vessel Level 1(e) SR 3.3.5.1.5 zero SR 3.3.5.1.6

b. Drywell Pressure - High(e) 1.2,3 4 B SR 3.3.5.1.2 s 2.5 psig SR 3.3.5.1.5 SR 3.3.5.1.6

c. Reactor Steam Dome 1,2,3 4 C SR 3.3.5.1.2 2: 435 psig and Pressure - Low (Injection SR 3.3.5.1.4 s 465 psig Permissive and ECCS SR 3.3.5.1.6 lnitiation)(e)

(continuedl (a) Deleted.

(b) Deleted.

ce) During instrument calibrations, if the As Found channel setpoint is conservative with respect to the Allowable Value bu1 outside its acceptable As Found band as defined by its associated Surveillance Requirement procedure, then there shall be an initial determination to ensure confidence that the channel can perform as required before returning the channel to service in accordance with the Surveillance. If the As Found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

Prior to returning a channel to service, the instrument channel setpoint shall be calibrated to a value that is within the acceptable As Left tolerance of the setpoint; otherwise, the channel shall be declared inoperable.

The nominal Trip Setpoint shall be specified on design output documentation which is incorporated by reference in the Updated Final Safety Analysis Report. The methodology used to determine the nominal Trip Setpoint, the predefined As Found Tolerance, and the As Left Tolerance band, and a listing of the setpoint design output documentation shall be specified in Chapter 7 of the Updated Final Safety Analysis Report.

BFN-UNIT 1 3.3-43 Amendment No.~.~. 311

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 3 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED FUNCTION OR OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER REQUIRED REQUIREMENTS VALUE CONDITIONS FUNCTION ACTIONA.1

2. LPCI System (continued)

d. Reactor Steam Dome 4 C SR 3.3.5.1.2 ~ 215 psig Pressure - Low SR 3.3.5.1.4 and (Recirculation Discharge SR 3.3.5.1.6 s 245 psig Valve Permissive)(e)

e. Reactor Vessel Water 1,2,3 2 B SR 3.3.5.1.1 ~ 312 5/16 Level - Level 0 1 per SR 3.3.5.1.2 inches above subsystem SR 3.3.5.1.5 vessel zero SR 3.3.5.1.6

f. Low Pressure Coolant Injection Pump Start - Time Delay Relay Pump A,B,C,D (with diesel 1,2,3 4 C SR 3.3.5.1.5 ~ 0 seconds power) SR 3.3.5.1.6 and s 1 second Pump A (with normal power) 1,2,3 C SR 3.3.5.1.5 ~ O seconds SR 3.3.5.1.6 and s 1 second Pump B (with normal power) 1,2,3 C SR 3.3.5.1.5 ~ 6 seconds SR 3.3.5.1.6 and s 8 seconds Pump C (with normal power) 1,2,3 C SR 3.3.5.1.5 ~ 12 seconds SR 3.3.5.1.6 and s 16 seconds Pump D (with normal power) 1.2.3 C SR 3.3.5.1.5 ~ 18 seconds SR 3.3.5.1.6 and s 24 seconds (continued~

(a) Deleted.

(c) With associated recirc~lation pump discharge valve open.

(e) During instrument calibrations, if the As Found channel setpoint is conservative with respect to the Allowable Value but outside its acceptable As Found band as defined by its associated Surveillance Requirement procedure, then there shall be an initial determination to ensure confidence that the channel can perform as required before returning the channel to service in accordance with the Surveillance. If the As Found instrument channel setpoint is not conservative with respect to the Allowable Value. the channel shall be declared inoperable.

Prior to returning a channel to service, the instrument channel setpoint shall be calibrated to a value that is within the acceptable As Left tolerance of the setpoint; otherwise. the channel shall be declared inoperable.

The nominal Trip Setpoint shall be specified on design output documentation which is incorporated by reference in the Updated Final Safety Analysis Report. The methodology used to determine the nominal Trip Setpoint, the predefined As Found Tolerance, and the As Left Tolerance band, and a listing of the setpoint design output documentation shall be specified in Chapter 7 of the Updated Final Safety Analysis Report.

BFN-UNIT 1 3.3-44 Amendment No.~.~.~. 311

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control Instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

. --NOTE----------------------------------------------

Separate Condition entry is allowed, for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A. 1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.2-1 for the channel.

B. As required by Required B.1 Declare associated Immediately Action A.1 and referenced penetration flow path(s) in Table 3.3.5.2-1. incapable of automatic isolation.

AND B.2 Calculate DRAIN TIME. Immediately C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.5.2-1.

(continued)

BFN-UNIT 1 3.3-47a Amendment No. 311

RPV Water Inventory Control Instrumentation 3'.3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. As required by Required D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and referenced OPERABLE status.

in Table 3.3.5.2-1.

E. Required Action and E.1 Declare associated low Immediately associated Completion pressure Emergency Time of Condition C or D Core Cooling System not met. (ECCS) injection/spray subsystem inoperable.

SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. 92 days BFN-UNIT 1 3.3-47b Amendment No. 311

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3. 5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

1. Core Spray System

a. Reactor 4, 5 2 per C SR 3.3.5.2.1 s465 psig Steam Dome trip system<*> SR 3.3.5.22 Pressure - Low (Injection Permissive)

b. Core Spray Pump 4,5 1 per D SR 3.3.5.2.2 ?. 1647 gpm Discharge Flow - subsystem<*> and Low (Bypass) s 2910 gpm

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Steam 4,5 2 in one trip C SR 3.3.5.2.1 s 465 psig Dome Pressure - system<*> SR 3.3.5.2.2 Low (Injection Permissive)

3. Shutdown Cooling System Isolation

a. Reactor Vessel (b) 1 per trip B SR 3.3.5.2.1 ?. 528 inches Water Level - Low, system SR 3.3.5.2.2 above vessel Level3 zero

4. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel (b) 1 per trip B SR 3.3.5.2.1 ?. 528 inches Water Level - Low, system SR 3.3.5.2.2 above vessel Level3 zero (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control."

(b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

BFN-UNIT 1 3.3-47c Amendment No. 311

RCIC System Instrumentation 3.3.5.3 3.3 INSTRUMENTATION 3.3.5.3 Reactor Core Isolation Cooling (RCIC) System Instrumentation LCO 3.3.5.3 The RCIC System instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

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

ACTIONS

~----------------------------------NOTE---------------------------------------------------

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A. 1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.3-1 for the channel.

B. As required by Required B.1 Declare RCIC System 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from Action A.1 and referenced inoperable. discovery of loss in Table 3.3.5.3-1. of RCIC initiation capability AND B.2 Place channel in trip. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

BFN-UNIT 1 3.3-48 Amendment No. 234, 311

RCIC System Instrumentation 3.3.5.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. As required by Required C.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and referenced OPERABLE status.

in Table 3.3.5.3-1.

D. Required Action and D.1 Declare RCIC System Immediately associated Completion inoperable.

Time of Condition 8 or C not met.

BFN-UNIT 1 3.3-49 Amendment No.~. 311

RCIC System Instrumentation 3.3.5.3 SURVEILLANCE REQUIREMENTS

N()TES-------------------------~-----------

1. Refer to Table 3.3.5.3-1 to determine which SRs apply for each RCIC Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 2 and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 1 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.3.5.3.2 Perform CHANNEL FUNCTl()NAL TEST. 92 days SR 3.3.5.3.3 Perform CHANNEL CALIBRATl()N. 24 months SR 3.3.5.3.4 Perform L()GIC SYSTEM FUNCTl()NAL 24 months TEST.

BFN-UNIT 1 3.3-50 Amendment No. 234,263, 311

RCIC System Instrumentation 3.3.5.3 Table 3.3.5.3-1 (page 1 of 1)

Reactor Core Isolation Cooling System Instrumentation CONDITIONS REQUIRED REFERENCED SURVEILLANCE ALLOWABLE FUNCTION CHANNELS PER FROM REQUIRED REQUIREMENTS VALUE FUNCTION ACTION A.1

1. Reactor Vessel Water 4 B SR 3.3.5.3.1 ~470 inches Level - Low Low, Level 2(a) SR 3.3.5.3.2 above vessel zero SR 3.3.5.3.3 SR 3.3.5.3.4

2. Reactor Vessel Water 2 C SR 3.3.5.3.1 s 583 inches Level - High, Level 8 SR 3.3.5.3.2 above vessel zero SR 3.3.5.3.3 SR 3.3.5.3.4 (a) During instrument calibrations, if the As Found channel setpoint is conservative with respect to the Allowable Value but outside its acceptable As Found band as defined by its associated Surveillance Requirement procedure, then there shall be an initial determination to ensure confidence that the channel can perform as required before returning the channel to service in accordance with the Surveillance. If the As Found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

Prior to returning a channel to service, the instrument channel setpoint shall be calibrated to a value that is within the acceptable As Len tolerance of the setpoint; otherwise, the channel shall be declared inoperable.

The nominal Trip Setpoint shall be specified on design output documentation which is incorporated by reference in the Updated Final Safety Analysis Report. The methodology used to determine the nominal Trip Setpoint, the predefined As Found Tolerance, and the As Left Tolerance band, and a listing of the setpoint design output documentation shall be specified in Chapter 7 of the Updated Final Safety Analysis Report.

BFN-UNIT 1 3.3-51 Amendment No.~.~. 311

Primary Containment Isolation Instrumentation 3.3.6.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. As required by Required H.1 Declare standby liquid 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action C.1 and referenced control system (SLC) in Table 3.3.6.1-1. inoperable.

OR H.2 Isolate the Reactor Water 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Cleanup System.

I. As required by Required 1.1 Initiate action to restore Immediately Action C.1 and referenced channel to OPERABLE in Table 3.3.6.1-1. status.

BFN-UNIT 1 3.3-56 Amendment No. 234, 311

Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 3 of 3)

Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED FUNCTION OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER TRIP REQUIRED REQUIREMENTS VALUE CONDITIONS SYSTEM ACTION C.1

5. Reactor Water Cleanup (RWCU) System Isolation

a. Main Steam Valve Vault 1,2,3 2 F SR 3.3.6.1.2 s; 201°F Area Temperature - High SR 3.3.6.1.5 SR 3.3.6.1.6

b. Pipe Trench Area 1,2,3 2 F SR 3.3.6.1.2 s; 135°F Temperature - High SR 3.3.6.1.5 SR 3.3.6.1.6 C. Pump Room A Area 1,2,3 2 F SR 3.3.6.1.2 s; 152°F Temperature - High SR 3.3.6.1.5 SR 3.3.6.1.6

d. Pump Room B Area 1,2,3 2 F SR 3.3.6.1.2 s; 152°F Temperature - High SR 3.3.6.1.5 SR 3.3.6.1.6

e. Heat Exchanger Room 1,2,3 2 F SR 3.3.6.1.2 s; 170°F Area (West Wall) SR 3.3.6.1.5 Temperature - High SR 3.3.6.1.6

f. Heat Exchanger Room 1,2,3 2 F SR 3.3.6.1.2 S 143'F Area (East Wall) SR 3.3.6.1.5 Temperature - High SR 3.3.6.1.6

g. SLC System Initiation 1,2,3 1(a) H SR 3.3.6.1.6 NA

h. Reactor Vessel Water 1,2,3 2 F SR 3.3.6.1.1 ~ 528 inches Level - Low, Level 3 SR 3.3.6.1.2 above vessel SR 3.3.6.1.5 zero SR 3.3.6.1.6

6. Shutdown Cooling System Isolation

a. Reactor Steam Dome 1.2.3 F SR 3.3.6.1.2 ,; 115 psig Pressure - High SR 3.3.6.1.5 SR 3.3.6.1.6

b. Reactor Vessel Water 3 2 SR 3.3.6.1. 1 ~ 528 inches Level - Low, Level 3 SR 3.3.6.1.2 above vessel SR 3.3.6.1.5 zero SR 3.3.6.1.6

c. Drywell Pressure - High 1,2,3 2 F SR 3.3.6.1.2 s; 2.5 psig SR 3.3.6.1.5 SR 3.3.6.1.6 (a) One SLC System Initiation signal provides logic input to close both RWCU valves.

(b) Deleted.

BFN-UNIT 1 3.3-60 Amendment Nos. a34, ~

2-ea, ~ . ~.311

Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2-1 (page 1 of 1)

Secondary Containment Isolation Instrumentation APPLICABLE MODES OR REQUIRED FUNCTION OTHER CHANNELS SURVEILLANCE ALLOWABLE SPECIFIED PER REQUIREMENTS VALUE CONDITIONS TRIP SYSTEM

1. Reactor Vessel Waler 1,2,3 2 SR 3.3.6.2.1 ~ 528 inches Level - Low. Level 3 SR 3.3.6.2.2 above vessel zero SR 3.3.6.2.3 SR 3.3.6.2.4

2. Drywell Pressure - High 1,2,3 2 SR 3.3.6.2.2 :. 2.5 psig SR 3.3.6.2.3 SR 3.3.6.2.4

3. Reactor Zone Exhaust 1,2,3 SR 3.3.6.2.1 :. 100 mR/hr Radiation - High SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4

4. Refueling Floor Exhaust 1,2,3 SR 3.3.6.2.1 :. 100 mR/hr Radiation - High SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4 BFN-UNIT 1 3.3-64 Amendment No. 2J.4, 2-a+, ~ . 311

CREV System Instrumentation 3.3.7.1 Table 3.3.7.1-1 (page 1 of 1)

Control Room Emergency Ventilation System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED FUNCTION OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER TRIP REQUIRED REQUIREMENTS VALUE CONDITIONS SYSTEM ACTION A.1

1. Reactor Vessel Water 1,2,3 2 B SR 3.3.7.1.1 ~ 528 inches Level - Low, Level 3 SR 3.3.7.1.2 abovevessel SR 3.3.7.1.5 zero SR 3.3.7.1.6

2. Drywell Pressure - High 1,2,3 2 B SR 3.3. 7.1.2 s 2.5 psig SR 3.3.7.1.5 SR 3.3.7.1.6

3. Reactor Zone Exhaust 1,2,3 C SR 3.3.7.1.1 s 100 mR/hr Radiation - High SR 3.3.7.1.2 SR 3.3.7.1.5 SR 3.3.7.1.6

4. Refueling Floor Exhaust 1,2,3 C SR 3.3.7.1.1 s 100 mR/hr Radiation - High SR 3.3.7.1.2 SR 3.3.7.1.5 SR 3.3.7.1.6

5. Control Room Air Supply Duct 1,2,3 D SR 3.3.7.1.1 s 270cpm Radiation - High SR 3.3.7.1.2 above SR 3.3.7.1.3 background SR 3.3.7.1.4 BFN-UNIT 1 3.3-69 Amendment No. 234, '* ~. 311

ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, 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.

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

(continued)

BFN-UNIT 1 3.5-1 Amendment No. 234, 24G, 249, 311

RPV Water Inventory Control 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be c!! 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND One low pressure ECCS injection/spray subsystem shall be OPERABLE.

NOTE--------------------------------~

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODES 4 and 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray subsystem injection/spray subsystem inoperable. to OPERABLE status.

B. Required Action and B.1 Initiate action to establish Immediately associated Completion a method of water Time of Condition A not injection capable of met. operating without offsite electrical power.

C. DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.1 Verify secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and c!! 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . containment boundary is capable of being established in less than the DRAIN TIME.

AND (continued}

BFN-UNIT 1 3.5-8 Amendment No.~. 311

RPV Water Inventory Control l 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify two standby gas 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months treatment subsystems are capable of being placed in operation in less than the DRAIN TIME.

D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . 0.1 ----------NOTE~----------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish Immediately an additional method of water injection with water sources capable of maintaining RPV water level > TAF for .:?: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND 0.2 Initiate action to establish Immediately secondary containment boundary.

AND (continued)

BFN-UNIT 1 3.5-9 Amendment No.~. 311

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.3 Initiate action to isolate Immediately each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

AND D.4 Initiate action to verify two Immediately standby gas treatment subsystems are capable of being placed in operation.

E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to 2: 36 Time of Condition C or D hours.

not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

BFN-UNIT 1 3.5-10 Amendment No.~. 311

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 2: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.5.2.2 Verify, for a required ECCS injection/spray 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months subsystem, the suppression pool water level is

~ -6.25 inches with or -7.25 inches without differential pressure control.

SR 3.5.2.3 Verify, for the required ECCS injection/spray 31 days subsystem, the piping is filled with water from the pump discharge valve to the injection valve.

SR 3.5.2.4 Verify, for the required ECCS injection/spray 31 days subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.2.5 Operate the required ECCS injection/spray 92 days subsystem through the test return line for 2: 1O minutes.

SR 3.5.2.6 Verify each valve credited for automatically 24 months isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

SR 3.5.2.7 ------------------------------NOTE-----------------------------

Vessel injection/spray may be excluded.

24 months Verify the required ECCS injection/spray subsystem can be manually operated.

BFN-UNIT 1 3.5-11 Amendment No.~. 2-eJ, W4, 311

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, 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

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

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 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 1 3.5-12 Amendment No. 234,249, 311

PCIVs 3.6.1.3 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

1. Penetration flow paths except for 18 and 20 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment," when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria.

~------------~---------------------------------

BFN-UNIT 1 3.6-9 Amendment No. 234,311

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. -------------NOTE---------- A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except for Only applicable to penetration flow path by main steam line penetration flow paths use of at least one closed with two PCIVs. and de-activated AND automatic valve, closed manual valve, blind 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main One or more penetration flange, or check valve steam line flow paths with one PCIV with flow through the inoperable except due to valve secured.

MSIV leakage not within limits.

(continued)

BFN-UNIT 1 3.6-10 Amendment No. U4, 311

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more penetration D.1 Restore leakage rate to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months flow paths with MSIV within limit.

leakage not within limits.

E. Required Action and E.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, B, AND C, or D not met.

E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BFN-UNIT 1 3.6-13 Amendment No.~. 311

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Secondary containment A.1 Restore secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months inoperable. containment 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 of Condition A not AND met.

8.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BFN-UNIT 1 3.6-44 Amendment No. ~ . 2a+, 311

Secondary Containment 3.6.4.1 This page intentionally left blank.

BFN-UNIT 1 3.6-45 Amendment No. 234, ~ . 311

SCIVs 3.6.4.2 3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Valves (SCIVs)

LCO 3.6.4.2 Each SCIV shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

1. Penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made inoperable by SCIVs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more penetration A.1 Isolate the affected 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months flow paths with one SC IV penetration flow path by inoperable. use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

(continued)

BFN-UNIT 1 3.6-47 Amendment No. 234, '-* 311

SCIVs 3.6.4.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 ~---~--~---NOTE---~~---~

Isolation devices in high radiation areas may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

B. -~-----------NOTE------------ 8.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Only applicable to penetration flow path by penetration flow paths use of at least one closed with two isolation valves. and de-activated

automatic valve, closed manual valve, or blind One or more penetration flange.

flow paths with two SC IVs inoperable.

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 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 BFN-UNIT 1 3.6-48 Amendment No. 234, 311

SCIVs 3.6.4.2 This page intentionally left blank.

BFN-UNIT 1 3.6-49 Amendment No. ~ ' ~ . 311

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Three SGT subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SGT subsystem A.1 Restore SGT subsystem 7 days 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 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 C. Two or three SGT C.1 Enter LCO 3.0.3. Immediately subsystems inoperable.

BFN-UNIT 1 3.6-51 Amendment No. 234, '-* 311

SGT System 3.6.4.3 This page intentionally left blank.

BFN-UNIT 1 3.. 6-52 Amendment No. 2M, 2&+, 311

SGT System 3.6.4.3 This page intentionally left blank.

BFN-UNIT 1 3.6-53 Amendment No. 2M, ~ . 311

CREV System 3.7.3

3. 7 PLANT SYSTEMS

3. 7 .3 Control Room Emergency Ventilation (CREV) System LCO 3.7.3 Two CREV subsystems shall be OPERABLE.

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

The main control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREV subsystem A.1 Restore CREV subsystem 7 days inoperable for reasons to OPERABLE status.

other than Condition B, C, or D.

8. One or more CREV 8.1 Initiate action to Immediately subsystems inoperable implement mitigating due to inoperable CRE actions boundary.

AND B.2 Verify mitigating actions 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ensure CRE occupant exposures to radiological hazards will not exceed limits, and verify the CRE occupants are protected from smoke and chemical hazards.

AND 8.3 Restore CRE boundary to 90 days OPERABLE status.

(continued)

BFN-UNIT 1 3.7-8 Amendment 2J.4., 246, ~ .

2-75, ~ . 311

CREV System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two CREV subsystems C.1 Restore HEPA filter and 7 days inoperable due to one charcoal adsorber to inoperable High OPERABLE status.

Efficiency Particulate Air (HEPA) filter or charcoal adsorbers which do not impact ability of CREV subsystems to meet flowrate requirements specified in the Ventilation Filter Testing Program (VFTP).

D. One CREV subsystem D.1 Restore charcoal 14 days inoperable due to adsorber to OPERABLE inoperable charcoal status.

adsorber which does not impact the ability of CREV subsystem to meet flowrate requirements specified in the VFTP.

E. Required Action and E.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, B, AND C, or D not met.

E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Two CREV subsystems F.1 Enter LCO 3.0.3. Immediately inoperable for reasons other than Condition B or C.

BFN-UNIT 1 3.7-9 Amendment~.~.~.

2-+a,~.311

CREV System 3.7.3 This page intentionally left blank.

BFN-UNIT 1 3.7-10 Amendment~.~.~.

zez, 311

Control Room AC System 3.7.4

3. 7 PLANT SYSTEMS

3. 7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Two Unit 1 and 2 control room AC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Unit 1 and 2 control A.1 Restore Unit 1 and 2 30 days room AC subsystem control room AC inoperable. subsystem to OPERABLE status.

(continued)

BFN-UNIT 1 3.7-12 Amendment No. 234, 311

Control Room AC System 3.7.4 ACTIONS {continued}

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 ------NOTE--------

associated Completion LCO 3.0.3 is not Time of Condition A or B applicable.

not met during movement of irradiated fuel assemblies in the Place OPERABLE control Immediately secondary containment or room AC subsystem in during CORE operation.

ALTERATIONS.

D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

BFN-UNIT 1 3.7-14 Amendment No.~. 311

AC Sources - Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to restore Immediately required offsite power circuit to OPERABLE status.

B. One or more required B.1 Suspend CORE Immediately Unit 1 and 2 DGs ALTERATIONS.

inoperable.

AND 8.2 Suspend movement of Immediately irradiated fuel assemblies in secondary containment.

AND B.3 Initiate action to restore Immediately required Unit 1 and 2 DGs to OPERABLE status.

(continued)

BFN-UNIT 1 3.8-16 Amendment No.~. 311

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 -----------------------N()TE------------------------

The following SRs are not required to be performed: SR 3.8.1.2, SR 3.8.1.5, SR 3.8.1.7, and SR 3.8.1.8.

For Unit 1 and 2 AC sources required to be In accordance

()PERABLE, the SRs of Specification 3.8.1 with applicable are applicable, except SR 3.8.1.6 and SRs SR 3.8.1.9.

SR 3.8.2.2 For the required Unit 3 DG, the SRs of Unit 3 In accordance Technical Specifications are applicable. with applicable SRs BFN-UNIT 1 3.8-18 Amendment No. ~ . 311

DC Sources - Shutdown 3.8.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to restore Immediately required DC electrical power subsystems or systems to OPERABLE status.

BFN-UNIT 1 3.8-27 Amendment No.~. 311

Distribution Systems - Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate actions to restore Immediately required AC and DC electrical power distribution subsystems to OPERABLE status.

A.2.4 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

BFN-UNIT 1 3.8-40 Amendment No. 234,311

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-260 BROWNS FERRY NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 334 Renewed License No. DPR-52

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated January 25, 2019, as supplemented by letter dated August 8, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-33 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 334, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

Enclosure 2

3. This license amendment is effective as of its date of issuance and because of shared-system complexity and to ensure uniform implementation across all three units, the amendments shall be implemented for all three units prior to the start of the interval beginning with the Browns Ferry Nuclear Plant, Unit 3, Spring 2022, Cycle 20, refueling outage (3U20).

Ff>R THE NUCLEAR REGULATORY COMMISSION

' *~11,' (",,

cl,

,_ i{lii{, t

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JndinJ S. Shoop, Chief

~-) . i I I Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: December 26, 2019

ATTACHMENT TO LICENSE AMENDMENT NO. 334 BROWNS FERRY NUCLEAR PLANT, UNIT 2 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-52 DOCKET NO. 50-260 Replace the following page of Renewed Facility Operating License No. DPR-52 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT 3 3 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT REMOVE INSERT 1.1-3 1.1-3 3.5-11 3.5-11 1.1-3a 3.5-12 3.5-12 3.3-37 3.3-37 3.6-9 3.6-9 3.3-38 3.3-38 3.6-10 3.6-10 3.3-39 3.3-39 3.6-13 3.6-13 3.3-43 3.3-43 3.6-44 3.6-44 3.3-44 3.3-44 3.6-45 3.6-45 3.3-45 3.3-45 3.6-47 3.6-47 3.3-48a 3.6-48 3.6-48 3.3-48b 3.6-49 3.6-49 3.3-48c 3.6-51 3.6-51 3.3-49 3.3-49 3.6-52 3.6-52 3.3-50 3.3-50 3.6-53 3.6-53 3.3-51 3.3-51 3.7-9 3.7-9 3.3-52 3.3-52 3.7-10 3.7-10 3.3-57 3.3-57 3.7-11 3.7-11 3.3-62 3.3-62 3.7-13 3.7-13 3.3-65 3.3-65 3.7-15 3.7-15 3.3-70 3.3-70 3.8-16 3.8-16 3.5-1 3.5-1 3.8-18 3.8-18 3.5-8 3.5-8 3.8-27 3.8-27 3.5-9 3.5-9 3.8-40 3.8-40 3.5-10 3.5-10

sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

( 1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3952 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 334, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 253 to Facility Operating License DPR-52, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 253. For SRs that existed prior to Amendment 253, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 253.

(3) The licensee is authorized to relocate certain requirements included in Appendix A and the former Appendix B to licensee-controlled documents.

Implementation of this amendment shall include the relocation of these requirements to the appropriate documents, as described in the licensee's BFN-UNIT 2 Renewed License No. DPR-52 Amendment No. 334

Definitions 1.1 1.1 Definitions (continued)

CORE OPERATING LIMITS The COLR is the unit specific document that provides REPORT (COLR) cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, 1-132, 1-133, 1-134, and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table Ill of TID-14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites."

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a. The water inventory above the TAF is divided by the limiting drain rate;

b. The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or (continued)

BFN-UNIT 2 1.1-3 Amendment No. 253, ~ . 334

Definitions 1.1 1.1 Definitions (continued)

DRAIN TIME (continued) automatic valves that are locked, sealed, or otheiwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation devices without offsite power.

c. The penetration flow paths required to be evaluated per paragraph b are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;

d. No additional draining events occur; and

e. Realistic cross-sectional areas and drain rates are used.

A bounding ORAN TIME may be used in lieu of a calculated value.

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

(continued)

BFN-UNIT 2 1.1-3a Amendment No. 334

EGGS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. As required by Required B.1 -------------NOTE------------

Action A.1 and Only applicable for referenced in Functions 1.a, 1.b, 2.a, Table 3.3.5.1-1.

and 2.b.

Declare supported ECCS 1 hourfrom feature(s) inoperable discovery of loss when its redundant of initiation feature ECCS initiation capability for capability is inoperable. features in both divisions AND B.2 --------------NOTE------------

Only applicable for Functions 3.a and 3.b.

Declare High Pressure 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from Coolant Injection (HPCI) discovery of loss System inoperable. of HPCI initiation capability AND B.3 Place channel in trip. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

BFN-UNIT 2 3.3-37 Amendment No.~. 334

ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. As required by Required C.1 -------------NOTE-------------

Action A.1 and Only applicable for referenced in Functions 1.c, 1.e, 2.c, 2.d, Table 3.3.5.1-1.

and 2.f.

Declare supported ECCS 1 hourfrom feature(s) inoperable discovery of loss when its redundant of initiation feature ECCS initiation capability for capability is inoperable. features in both divisions

/

AND C.2 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABJ,.E status.

D. As required by Required 0.1 --------------NOTE------------

Action A.1 and Only applicable if HPCI referenced in pump suction is not Table 3.3.5.1-1. aligned to the suppression pool.

Declare HPCI System 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable.

(continued)

BFN-UNIT 2 3.3-38 Amendment No. ~ . 334

ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. As required by Required E.1 -------------NOTE------------

Action A.1 and Only applicable for referenced in Function 1.d.

Table 3.3.5.1-1.

Declare supported ECCS 1 hourfrom feature(s) inoperable discovery of loss when its redundant of initiation feature ECCS initiation capability for capability is inoperable. subsystems in both divisions AND E.2 Restore channel to 7 days OPERABLE status.

(continued)

BFN-UNIT 2 3.3-39 Amendment No.~. 334

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1*1 (page 1 of6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED FUNCTION OR OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER REQUIRED REQUIREMENTS VALUE CONDITIONS FUNCTION ACTIONA.1

1. Core Spray System

a. Reactor Vessel Water 1,2,3 B SR 3.3.5.1.1 ~ 398 inches Level

Low Low Low, SR 3.3.5.1.2 above vessel Level 1(e) SR 3.3.5.1.5 zero SR 3.3.5.1.6

b. Drywell Pressure

1,2,3 B SR 3.3.5.1.2 s 2.5psig High(e) SR 3.3.5.1.5 SR 3.3.5.1.6

c. Reactor Steam Dome 1,2,3 4(b) C SR 3.3.5.1.2 ~435 psig Pressure - Low (Injection 2 per trip SR 3.3.5.1.4 and Permissive and ECCS system SR 3.3.5.1.6 s 465 psig lnitiation)(e)

d. Core Spray Pump 1,2,3 2 E SR 3.3.5.1.2 ~ 1647 gpm Discharge Flow - Low 1 per SR 3.3.5.1.5 and (Bypass) subsystem s 2910 gpm

e. Core Spray Pump Start

Time Delay Relay Pumps A,B,C,D (with 1,2,3 4 C SR 3.3.5.1.5 ~6 seconds diesel power) 1 per pump SR 3.3.5.1.6 and s 8 seconds Pump A (with normal 1,2,3 C SR 3.3.5.1.5 ~ 0 seconds power) SR 3.3.5.1.6 and s 1 second Pump B (with normal 1,2,3 C SR 3.3.5.1.5 ~ 6 seconds power) SR 3.3.5.1.6 and s 8 seconds continued (a) Deleted.

(b) Channels affect Common Accident Signal Logic. Refer to LCO 3.8.1, "AC Sources - Operating."

(e) During instrument calibrations, if the As Found channel setpoint is conservative with respect to the Allowable Value but outside its acceptable As Found band as defined by its associated Surveillance Requirement procedure, then there shall be an initial determination to ensure confidence that the channel can perform as required before returning the channel to service in accordance with the Surveillance. If the As Found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

Prior to returning a channel to service, the instrument channel setpoint shall be calibrated to a value that is within the acceptable As Left tolerance of the setpoint; otherwise, the channel shall be declared inoperable.

The nominal Trip Setpoint shall be specified on design output documentation which is incorporated by reference in the Updated Final Safety Analysis Report. The methodology used to determine the nominal Trip Setpoint, the predefined As Found Tolerance, and the As Left Tolerance band, and a listing of the setpoint design output documentation shall be specified in Chapter 7 of the Updated Final Safety Analysis Report.

BFN-UNIT 2 3.3-43 Amendment No. ~ . 2-99, 334

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 2 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED FUNCTION OR OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER REQUIRED REQUIREMENTS VALUE CONDITIONS FUNCTION ACTION A.1

1. Core Spray System (continued)

e. Core Spray Pump Start -

Time Delay Relay (continued)

Pump C (with normal power) 1,2,3 C SR 3.3.5.1.5 2: 12 seconds SR 3.3.5.1.6 and

S 16 seconds Pump D (with normal power) 1,2,3 C SR 3.3.5.1.5 2: 18 seconds SR 3.3.5.1.6 and

S 24 seconds

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Vessel Water 1,2,3 4 B SR 3.3.5.1.1 2: 398 inches Level - Low Low Low, SR 3.3.5.1.2 above vessel Level 1(e) SR 3.3.5.1.5 zero SR 3.3.5.1.6

b. Drywell Pressure - High(e) 1,2,3 4 B SR 3.3.5.1.2 :S 2.5 psig SR 3.3.5.1.5 SR 3.3.5.1.6

c. Reactor Steam Dome 1,2,3 4 C SR 3.3.5.1.2 2: 435 psig and Pressure - Low (Injection SR 3.3.5.1.4 :S 465 psig Permissive and ECCS SR 3.3.5.1.6 lnitiation)(e)

I (continued)

(a) Deleted. I (b) Deleted.

(e) During instrument calibrations, if the As Found channel setpoint is conservative with respect to the Allowable Value but outside its acceptable As Found band as defined by its associated Surveillance Requirement procedure, then there shall be an initial determination to ensure confidence that the channel can perform as required before returning the channel to service in accordance with the Surveillance. If the As Found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

Prior to returning a channel to service, the instrument channel setpoint shall be calibrated to a value that is within the acceptable As Left tolerance of the setpoint; otherwise, the channel shall be declared inoperable.

The nominal Trip Setpoint shall be specified on design output documentation which is incorporated by reference in the Updated Final Safety Analysis Report. The methodology used to determine the nominal Trip Setpoint, the predefined As Found Tolerance, and the As Left Tolerance band, and a listing of the setpoint design output documentation shall be specified in Chapter 7 of the Updated Final Safety Analysis Report.

BFN-UNIT 2 3.3-44 Amendment No.~.~. 334

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 3 of6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED FUNCTION OR OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER REQUIRED REQUIREMENTS VALUE CONDITIONS FUNCTION ACTIONA.1

2. LPCI System (continued)

d. Reactor Steam Dome 4 C SR 3.3.5.1.2 ~ 215 psig Pressure

Low SR 3.3.5.1.4 and s 245 psig (Recirculation Discharge SR 3.3.5.1.6 Valve Permissive)(e)

e. Reactor Vessel Water 1,2,3 2 B SR 3.3.5.1.1 ~ 312 5/16 Level

Level 0 1 per SR 3.3.5.1.2 inches above subsystem SR 3.3.5.1.5 vessel zero SR 3.3.5.1.6

f. Low Pressure Coolant Injection Pump Start - Time Delay Relay Pump A,B,C,D (with diesel 1,2,3 4 C SR 3.3.5.1.5 ~ O seconds power) SR 3.3.5.1.6 and

,.; 1 second Pump A (with normal power) 1,2,3 C SR 3.3.5.1.5 ~ O seconds SR 3.3.5.1.6 and

,.; 1 second Pump B (with normal power) 1,2,3 C SR 3.3.5.1.5 ~ 6 seconds SR 3.3.5.1.6 and s 8 seconds Pump C (with normal power) 1,2,3 C SR 3.3.5.1.5 ~ 12 seconds SR 3.3.5.1.6 and

,.; 16 seconds Pump D (with normal power) 1,2,3 C SR 3.3.5.1.5 ~ 18 seconds SR 3.3.5.1.6 and

,.; 24 seconds (continiJedl (a) Deleted.

(c) With associated recirculation pump discharge valve open.

(e) During instrument calibrations, if the As Found channel setpoint is conservative with respect to the Allowable Value but outside its acceptable As Found band as defined by its associated Surveillance Requirement procedure, then there shall be an initial determination to ensure confidence that the channel can perform as required before returning the channel to service in accordance with the Surveillance. If the As Found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

Prior to returning a channel to service, the instrument channel setpoint shall be calibrated to a value that is within the acceptable As Left tolerance of the setpoint; otherwise, the channel shall be declared inoperable.

The nominal Trip Setpoint shall be specified on design output documentation which is incorporated by reference in the Updated Final Safety Analysis Report. The methodology used to determine the nominal Trip Setpoint, the predefined As Found Tolerance, and the As Left Tolerance band, and a listing of the setpoint design output documentation shall be specified in Chapter 7 of the Updated Final Safety Analysis Report.

BFN-UNIT 2 3.3-45 Amendment No. ~ . ~ . ~ . 334

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV} Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control Instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.2-1 for the channel.

B. As required by Required 8.1 Declare associated Immediately Action A.1 and referenced penetration flow path( s) in Table 3.3.5.2-1. incapable of automatic isolation.

AND 8.2 Calculate DRAIN TIME. Immediately C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.5.2-1.

(continued)

BFN-UNIT 2 3.3-48a Amendment No. 334

RPV Water Inventory Control Instrumentation 3.3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. As required by Required D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and OPERABLE status.

referenced in Table 3.3.5.2-1.

E. Required Action and E.1 Declare associated tow Immediately associated Completion pressure Emergency Core Time of Condition C or D Cooling System (ECCS) not met. injection/spray subsystem inoperable.

SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. 92 days BFN-UNIT 2 3.3-48b Amendment No. 334

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

1. Core Spray System

a. Reactor 4, 5 2 per C SR 3.3.5.2.1 .,; 465 psig Steam Dome trip system(*> SR 3.3.5.2.2 Pressure - Low (Injection Permissive)

b. Core Spray Pump 4,5 1 per D SR 3.3.5.2.2 ~ 1647 gpm Discharge Flow - subsystem(a) and Low (Bypass) .,; 2910 gpm

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Steam 4,5 2 in one trip C SR 3.3.5.2.1 .,; 465 psig Dome Pressure - system(*> SR 3.3.5.2.2 Low (Injection Permissive)

3. Shutdown Cooling System Isolation

a. Reactor Vessel (b) 1 per trip B SR 3.3.5.2.1 ~ 528 inches Water Level - Low, system SR 3.3.5.2.2 above vessel Level3 zero

4. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel (b) 1 per trip B SR 3.3.5.2.1 ~ 528 inches Water Level - Low, system SR 3.3.5.2.2 above vessel Level3 zero (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control."

(b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

BFN-UNIT 2 3.3-48c Amendment No. 334

RCIC System Instrumentation 3.3.5.3 1 3.3 INSTRUMENTATION 3.3.5.3 Reactor Core Isolation Cooling (RCIC) System Instrumentation LCO 3.3.5.3 The RCIC System instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

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

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.3-1 for the channel.

B. As required by Required B.1 Declare RCIC System 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from Action A.1 and inoperable. discovery of loss referenced in of RCIC initiation Table 3.3.5.3-1. capability AND B.2 Place channel in trip. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

BFN-UNIT 2 3.3-49 Amendment No. 2-63, 334

RCIC System Instrumentation 3.3.5.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. As required by Required C.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and OPERABLE status.

referenced in Table 3.3.5.3-1.

D. Required Action and D.1 Declare RCIC System Immediately associated Completion inoperable.

Time of Condition B or C not met.

BFN-UNIT 2 3.3-50 Amendment No. ~ . 334

RCIC System Instrumentation 3.3.5.3 SURVEILLANCE REQUIREMENTS

N()TES--------------------------------------------------

1. Refer to Table 3.3.5.3-1 to determine which SRs apply for each RCIC Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 2 and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 1 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.3.5.3.2 Perform CHANNEL FUNCTl()NAL TEST. 92 days SR 3.3.5.3.3 Perform CHANNEL CALIBRATl()N. 24 months SR 3.3.5.3.4 Perform L()GIC SYSTEM FUNCTl()NAL 24 months TEST.

BFN-UNIT 2 3.3-51 Amendment No.~. 334

RCIC System Instrumentation 3.3.5.3 Table 3.3.5.3-1 (page 1 of 1)

Reactor Core Isolation Cooling System Instrumentation CONDITIONS REQUIRED REFERENCED SURVEILLANCE ALLOWABLE FUNCTION CHANNELS PER FROM REQUIRED REQUIREMENTS VALUE FUNCTION ACTION A.1

1. Reactor Vessel Water 4 B SR 3.3.5.3.1 ~ 470inches Level - Low Low, Level 2(a) SR 3.3.5.3.2 above vessel zero SR 3.3.5.3.3 SR 3.3.5.3.4

2. Reactor Vessel Water 2 C SR 3.3.5.3.1 s 583 inches Level - High, Level 8 SR 3.3.5.3.2 above vessel zero SR 3.3.5.3.3 SR 3.3.5.3.4 (a) During instrument calibrations, if the As Found channel setpoint is conservative with respect to the Allowable Value but outside its acceptable As Found band as defined by its associated Surveillance Requirement procedure, then there shall be an initial determination to ensure confidence that the channel can perform as required before returning the channel to service in accordance with the Surveillance. If the As Found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be dedared inoperable.

Prior to returning a channel to service, the instrument channel setpoint shall be calibrated to a value that is within the acceptable As Left tolerance of the setpoint; otherwise, the channel shall be dedared inoperable.

The nominal Trip Setpoint shall be specified on design output documentation which is incorporated by reference in the Updated Final Safety Analysis Report. The methodology used to determine the nominal Trip Setpoint, the predefined As Found Tolerance. and the As Left Tolerance band, and a listing of the setpoint design output documentation shall be specified in Chapter 7 of the Updated Final Safety Analysis Report.

BFN-UNIT 2 3.3-52 Amendment No.~.~. 334

Primary Containment Isolation Instrumentation 3.3.6.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. As required by Required H.1 Declare standby liquid 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action C.1 and control system (SLC) referenced in inoperable.

Table 3.3.6.1-1.

OR H.2 Isolate the Reactor Water 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Cleanup System.

I. As required by Required 1.1 Initiate action to restore Immediately Action C.1 and channel to OPERABLE referenced in status.

Table 3.3.6.1-1.

BFN-UNIT 2 3.3-57 Amendment No. ~ . 334

Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 3 of 3)

Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED FUNCTION OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER TRIP REQUIRED REQUIREMENTS VALUE CONDITIONS SYSTEM ACTION C.1

5. Reactor Water Cleanup (RWCU) System Isolation

a. Main Steam Valve Vault 1,2,3 2 F SR 3.3.6.1.2 s 188°F Area Temperature - High SR 3.3.6.1.5 SR 3.3.6. 1.6

b. Pipe Trench Area 1,2,3 2 F SR 3.3.6.1.2 s 135°F Temperature - High SR 3.3.6.1.5 SR 3.3.6.1.6 C. Pump Room A Area 1.2,3 2 F SR 3.3.6.1.2 s 152°F Temperature - High SR 3.3.6.1.5 SR 3.3.6.1.6

d. Pump Room B Area 1,2,3 2 F SR 3.3.6.1.2 s 152°F Temperature - High SR 3.3.6.1.5 SR 3.3.6.1.6

e. Heat Exchanger Room 1,2,3 2 F SR 3.3.6.1.2 s 143°F Area (West Wall) SR 3.3.6.1.5 Temperature - High SR 3.3.6.1.6

f. Heat Exchanger Room 1,2,3 2 F SR 3.3.6.1.2 s 170°F Area (East Wall) SR 3.3.6.1.5 Temperature - High SR 3.3.6.1.6

g. SLC System Initiation 1,2,3 1(a) H SR 3.3.6.1.6 NA

h. Reactor Vessel Water 1,2,3 2 F SR 3.3.6.1.1 2'. 528 inches Level - Low, Level 3 SR 3.3.6.1.2 above vessel SR 3.3.6.1.5 zero SR 3.3.6.1.6

6. Shutdown Cooling System Isolation

a. Reactor Steam Dome 1,2,3 F SR 3.3.6.1.2 S 115 psig Pressure - High SR 3.3.6.1.5 SR 3.3.6.1.6

b. Reactor Vessel Water 3 2 SR 3.3.6.1.1 2'. 528 inches Level - Low, Level 3 SR 3.3.6.1.2 above vessel SR 3.3.6.1.5 zero SR 3.3.6.1.6

c. Drywell Pressure - High 1,2,3 2 F SR 3.3.6.1.2 s 2.5 psig SR 3.3.6.1.5 SR 3.3.6. 1.6 (a) One SLC System Initiation signal provides logic input to close both RWCU valves.

(b) Deleted.

BFN-UNIT 2 3.3-62 Amendment No. ~ . ~ . 2-eG

'2:1-+.~.J4.9.334

Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2-1 (page 1 of 1)

Secondary Containment Isolation Instrumentation APPLICABLE MODES OR REQUIRED FUNCTION OTHER CHANNELS SURVEILLANCE ALLOWABLE SPECIFIED PER REQUIREMENTS VALUE CONDITIONS TRIP SYSTEM

1. Reactor Vessel Water 1,2,3 2 SR 3.3.6.2.1 ~ 528 inches Level

Low, Level 3 SR 3.3.6.2.2 above vessel zero SR 3.3.6.2.3 SR 3.3.6.2.4

2. Drywell Pressure - High 1,2,3 2 SR 3.3.6.2.2 s 2.5 psig SR 3.3.6.2.3 SR 3.3.6.2.4

3. Reactor Zone Exhaust 1,2,3 SR 3.3.6.2.1 s 100 mR/hr Radiation

High SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4

4. Refueling Floor Exhaust 1,2,3 SR 3.3.6.2.1 s 100 mR/hr Radiation - High SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4 BFN-UNIT 2 3.3-65 Amendment No.~. 2W, ~ . 334

CREV System Instrumentation 3.3.7.1 Table 3.3.7.1-1 (page 1 of 1)

Control Room Emergency Ventilation System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED FUNCTION OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER TRIP REQUIRED REQUIREMENTS VALUE CONDITIONS SYSTEM ACTIONA.1

1. Reactor Vessel Water 1,2,3 2 B SR 3.3.7.1.1 ~ 528 inches Level - Low, Level 3 SR 3.3.7.1.2 abovevessel SR 3.3.7.1.5 zero SR 3.3. 7.1.6

2. Drywell Pressure - High 1,2,3 2 B SR 3.3.7.1.2 5 2.5 psig SR 3.3.7.1.5 SR 3.3.7.1.6

3. Reactor Zone Exhaust 1,2,3 C SR 3.3.7.1.1 5100 mR/hr Radiation - High SR 3.3.7.1.2 SR 3.3.7.1.5 SR 3.3.7.1.6

4. Refueling Floor Exhaust 1,2,3 C SR 3.3.7.1.1 s 100 mR/hr Radiation - High SR 3.3.7.1.2 SR 3.3.7.1.5 SR 3.3.7.1.6

5. Control Room Air Supply Duct 1.2.3 D SR 3.3.7.1.1 5 270 cpm Radiation - High SR 3.3.7.1.2 above SR 3.3.7.1.3 background SR 3.3.7.1.4 BFN-UNIT 2 3.3-70 Amendment No. ~ . 200, 2QG, 334

ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, 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 5 150 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' 1l injection/spray subsystem ECCS injection/spray inoperable. subsystem(s) to OPERABLE status.

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

(continued) 1

( l- This Completion Time may be extended to 14 days on a one-time basis. This temporary approval expires June 1, 2005.

BFN-UNIT 2 3.5-1 Amendment No. ~ . ~ . 28e, 294,334

RPV Water Inventory Control 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

One low pressure ECCS injection/spray subsystem shall be OPERABLE.

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

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODES 4 and 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray subsystem injection/spray subsystem inoperable. to OPERABLE status.

B. Required Action and B.1 Initiate action to establish Immediately associated Completion a method of water Time of Condition A not injection capable of met. operating without offsite electrical power.

(continued)

BFN-UNIT 2 3.5-8 Amendment No. ~ . 334

RPV Water Inventory Control 3.5.2 ACTIONS {continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME< 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.1 Verify secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and 2: 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . containment boundary is capable of being established in less than the DRAIN TIME.

AND.

C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated inless than the DRAIN TIME.

AND C.3 Verify two standby gas 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months treatment subsystems are capable of being placed in operation in less than the DRAIN TIME.

D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.1 ------------NOTE-------------

Required ECCS injection/

spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an additional method of Immediately water injection with water sources capable of maintaining RPV water level > TAF for 2: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND (continued)

BFN-UNIT 2 3.5-9 Amendment No. 334

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.2 Initiate action to establish Immediately secondary containment boundary.

AND D.3 Initiate action to isolate Immediately each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

AND D.4 Initiate action to verify two Immediately standby gas treatment subsysems are capable of being placed in operation.

E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to ~ 36 Time of Condition C or D hours.

not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

BFN-UNIT 2 3.5-10 Amendment No. 334

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 2: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.5.2.2 Verify, for a required ECCS injection/spray 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months subsystem, the suppression pool water level is

~ -6.25 inches with or -7.25 inches without differential pressure control.

SR 3.5.2.3 Verify, for the required ECCS injection/spray 31 days subsystem, the piping is filled with water from the pump discharge valve to the injection valve.

SR 3.5.2.4 Verify, for the required ECCS injection/spray 31 days subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.2.5 Operate the required ECCS injection/spray 92 days subsystem through the test return line for 2: 10 minutes.

SR 3.5.2.6 Verify each valve credited for automatically 24 months isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

SR 3.5.2.7 ------------------------------NOTE-----------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray 24 months subsystem can be manually operated.

BFN-UNIT 2 3.5-11 Amendment No. 2ee, ~ . 334

RCICSystem 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, 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

NOTE--------.-----------------------------~----------

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 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 s 150 psig.

BFN-UNIT 2 3.5-12 Amendment No. 2&3, ~ . 334

PCIVs 3.6.1.3 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

- - - - - - - - - - - - - - - - - - - - - -,- NOTES----,

1. Penetration flow paths except for 18 and 20 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate* Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1 .1, "Primary Containment," when PCIV leakage results in exceeding overall containment leakage rat~ acceptance criteria.

BFN-UNIT 2 3.6-9 Amendment No. ~ . 334

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. ----------~--NOTE-~--------- A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except for Only applicable to penetration flow path by . main steam line penetration flow paths use of at least one closed with two PCIVs. and de-activated AND

automatic valve, closed manual valve, blind 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main One or more penetration flange, or check valve steam line flow paths with one PCIV with flow through the inoperable except due to valve secured.

MSIV leakage not within limits.

AND (continued}

BFN-UNIT 2 3.6-10 Amendment No.~. 334

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more penetration D.1 Restore leakage rate to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months flow paths with MSIV within limit.

leakage not within limits.

E. Required Action and E.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, B, AND C, or D not met.

E.2 Be in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BFN-UNIT 2 3.6-13 Amendment No.~. 334

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Secondary containment A.1 Restore secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months inoperable. containment to OPERABLE status.

B. Required Action and 8.1 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.

8.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BFN-UNIT 2 3.6-44 Amendment No. ~ . ~ . 334

Secondary Containment 3.6.4.1 This page intentionally left blank.

BFN-UNIT 2 3.6-45 Amendment No.~.~. 334

SCIVs 3.6.4.2 3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Valves (SCIVs)

LCO 3.6.4.2 Each SCIV shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

1. Penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made inoperable by SCIVs.

~-------------------------~---------------------------------~~---~------------~~~*------------

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more penetration A.1 Isolate the affected 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months flow paths with one SCIV penetration flow path by inoperable. use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

(continued)

BFN-UNIT 2 3.6-47 Amendment No. ~ . ~ . 334

SCIVs 3.6.4.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 ~------------NOTE------------

Isolation devices in high radiation areas may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

B. --------------NOTE------------ B.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Only applicable to penetration flow path by penetration flow paths use of at least one closed with two isolation valves. and de-activated

automatic valve, closed manual valve, or blind One or more penetration flange.

flow paths with two SCIVs inoperable.

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 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 BFN-UNIT 2 3.6-48 Amendment No. ~ . 334

SCIVs 3.6.4.2 This page intentionally left blank.

BFN-UNIT 2 3.6-49 Amendment No. ~ . ~ . 334

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Three SGT subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SGT subsystem A.1 Restore SGT subsystem 7 days 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 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 C. Two or three SGT C.1 Enter LCO 3.0.3. Immediately subsystems inoperable.

BFN-UNIT 2 3.6-51 Amendment No. ~ . 200, 334

SGT System 3.6.4.3 This page intentionally left blank.

BFN-UNIT 2 3.6-52 Amendment No.~.~. 334

SGT System 3.6.4.3 This page intentionally left blank.

BFN-UNIT 2 3.6-53 Amendment No.~.~. 334

CREV System 3.7.3

3. 7 PLANT SYSTEMS 3.7.3 Control Room Emergency Ventilation (CREV) System LCO 3.7.3 Two CREV subsystems shall be OPERABLE.

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

The main control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREV subsystem A.1 Restore CREV subsystem 7 days inoperable for reasons to OPERABLE status.

other than Condition B, C, or D.

B. One or more CREV B.1 Initiate action to Immediately subsystems inoperable implement mitigating due to inoperable CRE actions boundary.

AND B.2 Verify mitigating actions 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ensure CRE occupant exposures to radiological hazards will not exceed limits, and verify the CRE occupants are protected from smoke and chemical hazards.

AND B.3 Restore CRE boundary to 90 days OPERABLE status.

(continued)

BFN-UNIT 2 3.7-9 Amendment ~.-200.~.

~.334

CREV System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two CREV subsystems C.1 Restore HEPA filter and 7 days inoperable due to one charcoal adsorber to inoperable High OPERABLE status.

Efficiency Particulate Air (HEPA) filter or charcoal adsorbers which do not impact ability of CREV subsystems to meet flowrate requirements specified in the Ventilation Filter Testing Program (VFTP).

D. One CREV subsystem D.1 Restore charcoal 14 days inoperable due to adsorber to OPERABLE inoperable charcoal status.

adsorber which does not impact the ability of CREV subsystem to meet flowrate requirements specified in the VFTP.

E. Required Action and E.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, B, AND C, or D not met.

E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Two CREV subsystems F.1 Enter LCO 3.0.3. Immediately inoperable for reasons other than Condition B or C.

BFN-UNIT 2 3.7-10 Amendment 254, 28l, 290, 3GB, 334

CREV System 3.7.3 This page intentionally left blank.

BFN-UNIT 2 3.7-11 Amendment 283, 200, 392,

-388,334

Control Room AC System 3.7.4

3. 7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Two Unit 1 and 2 control room AC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Unit 1 and 2 control A.1 Restore Unit 1 and 2 30 days room AC subsystem control room AC inoperable. subsystem to OPERABLE status.

(continued)

BFN-UNIT 2 3.7-13 Amendment No. 2M, 334

Control Room AC System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 ----~-------NOTE-------------

associated Completion LCO 3.0.3 is not Time of Condition A or B applicable.

not met during movement ---------------------------------

of irradiated fuel assemblies in the Place OPERABLE control Immediately secondary containment or room AC subsystem in during CORE operation.

ALTERATIONS.

OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

BFN-UNIT 2 3.7-15 Amendment No. ~ . 334

AC Sources - Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to restore Immediately required offsite power circuit to OPERABLE status.

8. One or more required 8.1 Suspend CORE Immediately Unit 1 and 2 DGs ALTERATIONS.

inoperable.

AND 8.2 Suspend movement of Immediately irradiated fuel assemblies in secondary containment.

AND B.3 Initiate action to restore Immediately required Unit 1 and 2 DGs to OPERABLE status.

(continued)

BFN-UNIT 2 3.8-16 Amendment No.~. 334

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 --------------------------N()TE-------------------------

The following SRs are not required to be performed: SR 3.8.1.2, SR 3.8.1.5, SR 3.8.1.7, and SR 3.8.1.8.

For Unit 1 and 2 AC sources required to be In accordance OPERABLE, the SRs of Specification 3.8.1 with applicable are applicable, except SR 3.8.1.6 and SR SRs 3.8.1.9.

SR 3.8.2.2 For the required Unit 3 DG, the SRs of Unit 3 In accordance Technical Specifications are applicable. with applicable SRs BFN-UNIT 2 3.8-18 Amendment No.~. 334

DC Sources - Shutdown 3.8.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to restore Immediately required DC electrical power subsystems or systems to OPERABLE status.

BFN-UNIT 2 3.8-27 Amendment No.~. 334

Distribution Systems - Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate actions to restore Immediately required AC and DC electrical power distribution subsystems to OPERABLE status.

A.2.4 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

BFN-UNIT 2 3.8-40 Amendment No.~. 334

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-296 BROWNS FERRY NUCLEAR PLANT, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 294 Renewed License No. DPR-68

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated January 25, 2019, as supplemented by letter dated August 8, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-68 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 294, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

Enclosure 3

3. This license amendment is effective as of its date of issuance and because of shared-system complexity and to ensure uniform implementation across all three units, the amendments shall be implemented for all three units prior to the start of the interval beginning with the Browns Ferry Nuclear Plant, Unit 3, Spring 2022, Cycle 20, refueling outage (3U20).

F~;:NUf~~::T:~~MMISSION

. U~ine S. Shoop, Chief ,-J C Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: December 26, 2019

ATTACHMENT TO LICENSE AMENDMENT NO. 294 BROWNS FERRY NUCLEAR PLANT, UNIT 3 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-68 DOCKET NO. 50-296 Replace the following page of Renewed Facility Operating License No. DPR-68 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT 3 3 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT REMOVE INSERT 1.1-3 1.1-3 3.5-11 3.5-11 1.1-3a 3.5-12 3.5-12 3.3-37 3.3-37 3.6-9 3.6-9 3.3-38 3.3-38 3.6-10 3.6-10 3.3-39 3.3-39 3.6-13 3.6-13 3.3-43 3.3-43 3.6-44 3.6-44 3.3-44 3.3-44 3.6-45 3.6-45 3.3-45 3.3-45 3.6-47 3.6-47 3.3-48a 3.6-48 3.6-48 3.3-48b 3.6-49 3.6-49 3.3-48c 3.6-51 3.6-51 3.3-49 3.3-49 3.6-52 3.6-52 3.3-50 3.3-50 3.6-53 3.6-53 3.3-51 3.3-51 3.7-9 3.7-9 3.3-52 3.3-52 3.7-10 3.7-10 3.3-57 3.3-57 3.7-11 3.7-11 3.3-61 3.3-61 3.7-13 3.7-13 3.3-65 3.3-65 3.7-15 3.7-15 3.3-70 3.3-70 3.8-16 3.8-16 3.5-1 3.5-1 3.8-18 3.8-18 3.5-8 3.5-8 3.8-27 3.8-27 3.5-9 3.5-9 3.8-40 3.8-40 3.5-10 3.5-10

(3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3952 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 294, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 212 to Facility Operating License DPR-68, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 212. For SRs that existed prior to Amendment 212, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 212.

BFN-UNIT 3 Renewed License No. DPR-68 Amendment No. 294

Definitions 1.1 1.1 Definitions ( continued)

CORE OPERATING LIMITS The COLR is the unit specific document that provides REPORT (COLR) cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, 1-132, 1-133, 1-134, and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table Ill of TID-14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites."

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel

( RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a. The water inventory above the TAF is divided by the limiting drain rate;

b. The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the T AF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths; (continued)

BFN-UNIT 3 1.1-3 Amendment No.~.~. 294

Definitions 1.1 1.1 Definitions ( continued)

DRAIN TIME (continued) 2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation devices without offsite power.

c. The penetration flow paths required to be evaluated per paragraph b are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;

d. No additional draining events occur; and

e. Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

(continued)

BFN-UNIT 3 1.1-3a Amendment No. 294

ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. As required by Required B.1 --------------NOTE-------------

Action A. 1 and Only applicable for referenced in Functions 1.a, 1.b, 2.a, Table 3.3.5.1-1.

and 2.b.

Declare supported ECCS 1 hourfrom feature(s) inoperable discovery of loss when its redundant of initiation feature ECCS initiation capability for capability is inoperable. features in both divisions AND B.2 --------------NOTE------------

Only applicable for Functions 3.a and 3.b.

Declare High Pressure 1 hourfrom Coolant Injection (HPCI) discovery of loss System inoperable. of HPCI initiation capability AND B.3 Place channel in trip. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

BFN-UNIT 3 3.3-37 Amendment No.~. 294

ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. As required by Required C.1 --------------NOTE-------------

Action A.1 and Only applicable for referenced in Functions 1.c, 1.e, 2.c, Table 3.3.5.1-1.

2.d, and 2.f.

Declare supported ECCS 1 hourfrom feature(s) inoperable discovery of loss when its redundant of initiation feature ECCS initiation capability for capability is inoperable. features in both divisions AND C.2 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

D. As required by Required D.1 --------------NOTE------------

Action A.1 and Only applicable if HPCI referenced in pump suction is not Table 3.3.5.1-1. aligned to the suppression pool.

Declare HPC I System 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable.

(continued)

BFN-UNIT 3 3.3-38 Amendment No.~. 294

ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. As required by Required E.1 -------------NOTE------------

Action A.1 and Only applicable for referenced in Function 1.d.

Table 3.3.5.1-1.

Declare supported ECCS 1 hourfrom feature(s) inoperable discovery of loss when its redundant of initiation feature ECCS initiation capability for capability is inoperable. subsystems in both divisions E.2 Restore channel to 7 days OPERABLE status.

(continued)

BFN-UNIT 3 3.3-39 Amendment No. ~ . 294

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 1 of6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED FUNCTION OR OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER REQUIRED REQUIREMENTS VALUE CONDITIONS FUNCTION ACTIONA.1

1. Core Spray System

a. Reactor Vessel Water Level 1,2,3 B SR 3.3.5.1.1 :e: 398 inches

- Low Low Low, Level 1(0 SR 3.3.5.1.2 above vessel SR 3.3.5.1.5 zero SR 3.3.5.1.6

b. Drywell Pressure - High(f) 1,2,3 B SR 3.3.5.1.2 :5 2.5 psig SR 3.3.5.1.5 SR 3.3.5.1.6

c. Reactor Steam Dome 1,2,3 4(b) C SR 3.3.5.1.2 :e: 435 psig and Pressure - Low (Injection 2 per trip SR 3.3.5.1.4 :5 465 psig Permissive and ECCS system SR 3.3.5.1.6 lnitiation)(f)

d. Core Spray Pump Discharge 1,2,3 2 E SR 3.3.5.1.2 :e: 1647 gpm Flow-Low (Bypass) 1 per SR 3.3.5.1.5 and subsystem s 2910 gpm

e. Core Spray Pump Start -

Time Delay Relay Pumps A,B,C,D (with diesel 1,2,3 4 C SR 3.3.5.1.5 ;:: 6 seconds power) 1 per pump SR 3.3.5.1.6 and s 8 seconds Pump A (with normal power) 1,2,3 C SR 3.3.5.1.5 :e: 0 seconds SR 3.3.5.1.6 and s 1 second Pump B (with normal power) 1,2,3 C SR 3.3.5.1.5 :e: 6 seconds SR 3.3.5.1.6 and s 8 seconds (continued)

(a) Deleted.

(b) Channels affect Common Accident Signal Logic. Refer to LCO 3.8.1, "AC Sources - Operating."

(I) During instrument calibrations, if the As Found channel setpoint is conservative with respect to the Allowable Value but outside its acceptable As Found band as defined by its associated Surveillance Requirement procedure, then there shall be an initial determination to ensure confidence that the channel can perform as required before returning the channel to service in accordance with the Surveillance. If the As Found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

Prior to returning a channel to service, the instrument channel setpoint shall be calibrated to a value that is within the acceptable As Left tolerance of the setpoint; otherwise, the channel shall be declared inoperable.

The nominal Trip Setpoint shall be specified on design output documentation which is incorporated by reference in the Updated Final Safety Analysis Report. The methodology used to determine the nominal Trip Setpoint, the predefined As Found Tolerance, and the As left Tolerance band, and a listing of the setpoint design output documentation shall be specified in Chapter 7 of the Updated Final Safety Analysis Report.

BFN-UNIT 3 3.3-43 Amendment No. ~ . ~ . 294

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 2 of6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED FUNCTION OR OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER REQUIRED REQUIREMENTS VALUE CONDITIONS FUNCTION ACTION A.1

1. Core Spray System (continued)

e. Core Spray Pump Start-Time Delay Relay (continued)

Pump C (with normal power) 1,2,3 C SR 3.3.5.1.5 ?. 12 seconds SR 3.3.5.1.6 and s 16 seconds Pump D (with normal power) 1,2,3 C SR 3.3.5.1.5 ?. 18 seconds I SR 3.3.5.1.6 and s 24 seconds

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Vessel Water Level 1,2,3 4 B SR 3.3.5.1.1 ?. 398 inches

- Low Low Low, Level 1(f) SR 3.3.5.1.2 above vessel SR 3.3.5.1.5 zero SR 3.3.5.1.6

b. Drywell Pressure - High(f) 1,2,3 4 B SR 3.3.5.1.2 s 2.5 psig SR 3.3.5.1.5 SR 3.3.5.1.6

c. Reactor Steam Dome 1,2,3 4 C SR 3.3.5.1.2 ?. 435 psig and Pressure - Low (Injection SR 3.3.5.1.4 s465 psig Permissive and ECCS SR 3.3.5.1.6 lnitiation)(f)

(continued)

(a) Deleted.

(b) Deleted.

(t) During instrument calibrations, if the As Found channel setpoint is conservative with respect to the Allowable Value but outside its acceptable As Found band as defined by its associated Surveillance Requirement procedure, then there shall be an initial determination to ensure confidence that the channel can perform as required before returning the channel to service in accordance with the Surveillance. If the As Found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

Prior to returning a channel to service, the instrument channel setpoint shall be calibrated to a value that is within the acceptable As Left tolerance of the setpoint; otherwise, the channel shall be declared inoperable.

The nominal Trip Setpoint shall be specified on design output documentation which is incorporated by reference in the Updated Final Safety Analysis Report. The methodology used to determine the nominal Trip Setpoint, the predefined As Found Tolerance, and the As Left Tolerance band, and a listing of the setpoint design output documentation shall be specified in Chapter 7 of the Updated Final Safety Analysis Report.

BFN-UNIT 3 3.3-44 Amendment No. 24-a, 2&-4, 294

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 3 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED FUNCTION OR OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER REQUIRED REQUIREMENTS VALUE CONDITIONS FUNCTION ACTION A.1

2. LPCI System (continued)

d. Reactor Steam Dome 1(c),2(c), 4 C SR 3.3.5.1.2 2c215psig Pressure - Low 3(c) SR 3.3.5.1.4 and s 245 psig (Recirculation Discharge SR 3.3.5.1.6 Valve Permissive)(f)

e. Reactor Vessel Water Level 1,2,3 2 B SR 3.3.5.1.1 :1: 312 5/16

-LevelO 1 per SR 3.3.5.1.2 inches above subsystem SR 3.3.5.1.5 vessel zero SR 3.3.5.1.6

f. Low Pressure Coolant Injection Pump Start - Time Delay Relay Pump A,B,C,D (with diesel 1,2,3 4 C SR 3.3.5.1.5 ;,, 0 seconds power) SR 3.3.5.1.6 and s 1 second Pump A (with normal power) 1,2,3 C SR 3.3.5.1.5 :1: 0 seconds SR 3.3.5.1.6 and s 1 second Pump B (with normal power) 1,2,3 C SR 3.3.5.1.5 ~ 6 seconds SR 3.3.5.1.6 and s 8 seconds Pump C (with normal power) 1,2,3 C SR 3.3.5.1.5 ;,, 12 seconds SR 3.3.5.1.6 and s 16 seconds Pump D (with normal power) 1,2,3 C SR 3.3.5.1.5 ;,, 18 seconds SR 3.3.5.1.6 and s 24 seconds (continued}

(a) Deleted.

(c) With associated recirculation pump discharge valve open.

(f) During instrument calibrations, if the As Found channel setpoint is conservative with respect to the Allowable Value but outside its acceptable As Found band as defined by its associated Surveillance Requirement procedure, then there shall be an initial determination to ensure confidence that the channel can perform as required before returning the channel to service in accordance with the Surveillance. If the As Found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

Prior to returning a channel to service, the instrument channel setpoint shall be calibrated to a value that is within the acceptable As Left tolerance of the setpoint; otherwise, the channel shall be declared inoperable.

The nominal Trip Setpoint shall be specified on design output documentation which is incorporated by reference in the Updated Final Safety Analysis Report. The methodology used to determine the nominal Trip Setpoint, the predefined As Found Tolerance, and the As Left Tolerance band, and a listing of the setpoint design output documentation shall be specified in Chapter 7 of the Updated Final Safety Analysis Report.

BFN-UNIT 3 3.3-45 Amendment No. ~ . ~ . ~ . 294

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control Instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.2-1 for the channel.

B. As required by Required 8.1 Declare associated Immediately Action A.1 and referenced penetration flow path(s) in Table 3.3.5.2-1. incapable of automatic isolation.

AND 8.2 Calculate DRAIN TIME. Immediately C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.5.2-1.

(continued)

BFN-UNIT 3 3.3-48a Amendment No. 294

RPV Water Inventory Control Instrumentation 3.3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. As required by Required D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and referenced OPERABLE status.

in Table 3.3.5.2-1.

E. Required Action and E.1 Declare associated low Immediately associated Completion pressure Emergency Time of Condition C or D Core Cooling System not met. (ECCS) injection/spray subsystem inoperable.

SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. 92 days BFN-UNIT 3 3.3-48b Amendment No. 294

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Inst rumen! at ion APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

1. Core Spray System

a. Reactor 4, 5 2 per C SR 3.3.5.2.1 :,; 465 psig Steam Dome trip system(*> SR 3.3.5.2.2 Pressure - Low (Injection Pennissive)

b. Core Spray Pump 4, 5 1 per D SR 3.3.5.2.2 ~ 1647 gpm Discharge Flow - subsystem(*> and Low (Bypass) :,; 2910 gpm

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Steam 4, 5 2 in one trip C SR 3.3.5.2.1 :,; 465 psig Dome Pressure - system(*> SR 3.3.5.2.2 Low (Injection Pennissive)

3. Shutdown Cooling System Isolation

a. Reactor Vessel (b) 1 per trip B SR 3.3.5.2.1 ~ 528 inches Water Level - Low, system SR 3.3.5.2.2 above vessel Level3 zero

4. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel (b) 1 per trip B SR 3.3.5.2.1 ~ 528 inches Water Level - Low, system SR 3.3.5.2.2 above vessel Level 3 zero (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control."

(b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

BFN-UNIT 3 3.3-48c Amendment No. 294

RCIC System Instrumentation 3.3.5.3 3.3 INSTRUMENTATION 3.3.5.3 Reactor Core Isolation Cooling (RCIC) System Instrumentation LCO 3.3.5.3 The RCIC System instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

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

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.3-1 for the channel.

8. As required by Required 8.1 Declare RCIC System 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from Action A.1 and inoperable. discovery of loss referenced in of RCIC initiation Table 3.3.5.3-1. capability AND 8.2 Place channel in trip. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

BFN-UNIT 3 3.3-49 Amendment No. 243, 294

RCIC System Instrumentation 3.3.5.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. As required by Required C.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and OPERABLE status.

referenced in Table 3.3.5.3-1.

D. Required Action and D.1 Declare RCIC System Immediately associated Completion inoperable.

Time of Condition B or C not met.

BFN-UNIT 3 3.3-50 Amendment No. 24J, 294

RCIC System Instrumentation 3.3.5.3 SURVEILLANCE REQUIREMENTS

N()TES--------------------------------------------------

1. Refer to Table 3.3.5.3-1 to determine which SRs apply for each RCIC Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 2 and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 1 provided the associated Function maintains RCIC initiation capability.

~----~~-----------------------------------------------------------------------------------

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.5.3.3 Perform CHANNEL CALIBRATION. 24 months SR 3.3.5.3.4 Perform LOGIC SYSTEM FUNCTIONAL 24 months TEST.

BFN-UNIT 3 3.3-51 Amendment No. 24-§, 294

RCIC System Instrumentation 3.3.5.3 Table 3.3.5.3-1 (page 1 of 1)

Reactor Core Isolation Cooling System Instrumentation CONDITIONS REQUIRED REFERENCED SURVEILLANCE ALLOWABLE FUNCTION CHANNELS PER FROM REQUIRED REQUIREMENTS VALUE FUNCTION ACTIONA.1

1. Reactor Vessel Water 4 B SR 3.3.5.3. 1 ~ 470 inches Level - Low Low, Level 2(a) SR 3.3.5.3.2 above vessel zero SR 3.3.5.3.3 SR 3.3.5.3.4

2. Reactor Vessel Water 2 C SR 3.3.5.3.1 s 583 inches Level - High, Level 8 SR 33.5.3.2 above vessel zero SR 3.3.5.3.3 SR 3.3.5.3.4 (a) During instrument calibrations. if the As Found channel setpoint is conservative with respect to the Allowable Value but outside its acceptable As Found band as defined by its associated Surveillance Requirement procedure, then there shall be an initial determination to ensure confidence that the channel can perform as required before returning the channel to service in accordance with the Surveillance. If the As Found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

Prior to returning a channel to service, the instrument channel setpoint shall be calibrated to a value that is within the acceptable As Left tolerance of the setpoint; otherwise, the channel shall be declared inoperable.

The nominal Trip Setpoint shall be specified on design output documentation which is incorporated by reference in the Updated Final Safety Analysis Report. The methodology used to determine the nominal Trip Setpoint, the predefined As Found Tolerance, and the As Left Tolerance band, and a listing of the setpoint design output documentation shall be specified in Chapter 7 of the Updated Final Safety Analysis Report.

BFN-UNIT 3 3.3-52 Amendment No.~. 2M, 294

Primary Containment Isolation Instrumentation 3.3.6.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. As required by Required H.1 Declare standby liquid 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action C.1 and control system (SLC) referenced in inoperable.

Table 3.3.6.1-1.

OR H.2 Isolate the Reactor Water 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Cleanup System.

I. As required by Required 1.1 Initiate action to restore Immediately Action C.1 and channel to OPERABLE referenced in status.

Table 3.3.6.1-1.

BFN-UNIT 3 3.3-57 Amendment No. 24-J, 294

Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 3 of 3)

Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED FUNCTION OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER TRIP REQUIRED REQUIREMENTS VALUE CONDITIONS SYSTEM ACTION C.1

5. Reactor Water Cleanup (RWCU) System Isolation

a. Main Steam Valve Vault 1,2,3 2 F SR 3.3.6.1.2 s 201°F Area Temperature* High SR 3.3.6.1.5 SR 3.3.6.1.6

b. Pipe Trench Area 1,2,3 2 F SR 3.3.6.1.2 s 135°F Temperature - High SR 3.3.6.1.5 SR 3.3.6.1.6 C. Pump Room A Area 1,2,3 2 F SR 3.3.6.1.2 s 152°F Temperature* High SR 3.3.6.1.5 SR 3.3.6.1.6

d. Pump Room B Area 1,2,3 2 F SR 3.3.6.1.2 s 152°F Temperature - High SR 3.3.6.1.5 SR 3.3.6.1.6

e. Heat Exchanger Room 1,2,3 2 F SR 3.3.6.1.2 s 143°F Area (West Wall) SR 3.3.6.1.5 Temperature - High SR 3.3.6.1.6

f. Heat Exchanger Room 1,2,3 2 F SR 3.3.6.1.2 s 170'F Area (East Wall) SR 3.3.6.1.5 Temperature - High SR 3.3.6.1.6

g. SLC System Initiation 1,2,3 1(a) H SR 3.3.6.1.6 NA

h. Reactor Vessel Water 1,2,3 2 F SR 3.3.6.1.1 ,: 528 inches Level - Low, Level 3 SR 3.3.6.1.2 above vessel SR 3.3.6.1.5 zero SR 3.3.6.1.6

6. Shutdown Cooling System Isolation

a. Reactor Steam Dome 1,2,3 F SR 3.3.6.1.2 s 115 psig Pressure - High SR 3.3.6.1.5 SR 3.3.6.1.6

b. Reactor Vessel Water 3 2 SR 3.3.6.1.1 ,: 528 inches Level - Low, Level 3 SR 3.3.6.1.2 above vessel SR 3.3.6.1.5 zero SR 3.3.6.1.6 C. Drywell Pressure - High 1,2,3 2 F SR 3.3.6.1.2 s 2.5 psig SR 3.3.6.1.5 SR 3.3.6.1.6 (a) One SLC System Initiation signal provides logic input to close both RWCU valves.

(b) Deleted.

BFN-UNIT 3 3.3-61 Amendment No. ~ . ~ . iw

~.~.W-.294

Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2-1 (page 1 of 1)

Secondary Containment Isolation Instrumentation APPLICABLE MODES OR REQUIRED FUNCTION OTHER CHANNELS SURVEILLANCE ALLOWABLE SPECIFIED PER REQUIREMENTS VALUE CONDITIONS TRIP SYSTEM

1. Reactor Vessel Water 1,2,3 2 SR 3.3.6.2.1 :1: 528 inches Level - Low, Level 3 SR 3.3.6.2.2 above vessel zero SR 3.3.6.2.3 SR 3.3.6.2.4

2. Drywell Pressure - High 1,2,3 2 SR 3.3.6.2.2 s 2.5 psig SR 3.3.6.2.3 SR 3.3.6.2.4

3. Reactor Zone Exhaust 1,2,3 SR 3.3.6.2.1 s 100 mR/hr Radiation - High SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4

4. Refueling Floor Exhaust 1,2,3 SR 3.3.6.2.1 s 100 mR/hr Radiation - High SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4 BFN-UNIT 3 3.3-65 Amendment No. 212, 213,~.

~.294

GREV System Instrumentation 3.3.7.1 Table 3.3.7.1-1 (page 1 of1)

Control Room Emergency Ventilation System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED FUNCTION OTHER CHANNELS FROM SURVEILLANCE ALLOWABLE SPECIFIED PER TRIP REQUIRED REQUIREMENTS VALUE CONDITIONS SYSTEM ACTIONA.1

1. Reactor Vessel Water 1,2,3 2 B SR 3.3. 7.1.1 ~ 528 inches Level - Low, Level 3 SR 3.3.7.1.2 abovevessel SR 3.3.7.1.5 zero SR 3.3.7.1.6

2. Drywell Pressure - High 1,2,3 2 B SR 3.3. 7.1.2 s 2.5 psig SR 3.3. 7.1.5 SR 3.3.7.1.6

3. Reactor Zone Exhaust 1,2,3 C SR 3.3.7.1.1 s 100 mR/hr Radiation - High SR 3.3.7.1.2 SR 3.3. 7.1.5 SR 3.3.7.1.6

4. Refueling Floor Exhaust 1,2,3 C SR 3.3.7.1.1 s 100 mR/hr Radiation - High SR 3.3.7.1.2 SR 3.3.7.1.5 SR 3.3. 7.1.6

5. Control Room Air Supply Duct 1,2,3 D SR 3.3.7.1.1 s 270 cpm Radiation - High SR 3.3. 7.1.2 above SR 3.3.7.1.3 background SR 3.3,71.4 BFN-UNIT 3 3.3-70 Amendment No. i4a,, ~J. ~ . i49, 294

ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, 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 3 3.5-1 Amendment No. ~ . ~ . 244, 294

RPV Water Inventory Control 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be :::: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND One low pressure ECCS injection/spray subsystem shall be OPERABLE.

~---NOTE-------------------------------------------

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODES 4 and 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray subsystem injection/spray subsystem inoperable. to OPERABLE status.

B. Required Action and 8.1 Initiate action to establish Immediately associated Completion a method of water Time of Condition A not injection capable of met. operating without offsite electrical power.

(continued)

BFN-UNIT 3 3.5-8 Amendment No.~. 294

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.1 Verify secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and ~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . containment boundary is capable of being established in less than the DRAIN TIME.

AND C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify two standby gas 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months treatment subsystems are capable of being placed in operation in less than the DRAIN TIME.

D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . 0.1 ----------NOTE------------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish Immediately an additional method of water injection with water sources capable of maintaining RPV water level> TAF for~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND (continued)

BFN-UNIT 3 3.5-9 Amendment No.~. 294

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.2 Initiate action to establish Immediately secondary containment boundary.

AND D.3 Initiate action to isolate Immediately each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

AND D.4 Initiate action to verify two Immediately standby gas treatment subsystems are capable of being placed in operation.

E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to~ 36 Time of Condition C or D hours.

not met.

OR DRAIN TIME< 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

BFN-UNIT 3 3.5-10 Amendment No. ~ . 294

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.5.2.2 Verify, for a required ECCS injection/spray 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months subsystem, the suppression pool water level is

~ -6.25 inches with or -7.25 inches without differential pressure control.

SR 3.5.2.3 Verify, for the required ECCS injection/spray 31 days subsystem, the piping is filled with water from the pump discharge valve to the injection valve.

SR 3.5.2.4 Verify, for the required ECCS injection/spray 31 days subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.2.5 Operate the required ECCS injection/spray 92 days subsystem through the test return line for ~ 10 minutes.

SR 3.5.2.6 Verify each valve credited for automatically 24 months isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

SR 3.5.2.7 ---------~-~----------------NOTE-----------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray 24 months subsystem can be manually operated.

BFN-UNIT 3 3.5-11 Amendment No. 24-a, ~ . 294

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, 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

NOTE------------------------------------------------~

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 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 3 3.5-12 Amendment No.~.~. 294

PCIVs 3.6.1.3 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

1. Penetration flow paths except for 18 and 20 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment," when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria.

BFN-UNIT 3 3.6-9 Amendment No. ~ . 294

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. --------------NOTE------------ A. 1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except for Only applicable to penetration flow path by main steam line penetration flow paths use of at least one closed with two PCIVs. and de-activated AND automatic valve, closed manual valve, blind 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main One or more penetration flange, or check valve steam line flow paths with one PCIV with flow through the inoperable except due to valve secured.

MSIV leakage not within limits.

(continued)

BFN-UNIT 3 3.6-10 Amendment No.~. 294

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more penetration D.1 Restore leakage rate to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months flow paths with MSIV within limit.

leakage not within limits.

E. Required Action and E.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, B, AND C, or D not met. -

E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BFN-UNIT 3 3.6-13 Amendment No. ~ . 294

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Secondary containment A.1 Restore secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months inoperable. containment to OPERABLE status.

B. Required Action and 8.1 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.

8.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BFN-UNIT 3 3.6-44 Amendment No. ~ . 249, 294

Secondary Containment 3.6.4.1 This page intentionally left blank.

BFN-UNIT 3 3.6-45 Amendment No.~.~. 294

SCIVs 3.6.4.2 3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Valves (SCIVs)

LCO 3.6.4.2 Each SCIV shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

1. Penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made inoperable by SCIVs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more penetration A.1 Isolate the affected 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months flow paths with one SCIV penetration flow path by inoperable. use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

(continued)

BFN-UNIT 3 3.6-47 Amendment No.~.~. 294

SCIVs 3.6.4.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 ~------------NOTE------------

Isolation devices in high radiation areas may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

B. --------------NOTE------------ 8.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Only applicable to penetration flow path by penetration flow paths use of at least one closed with two isolation valves. and de-activated

automatic valve, closed manual valve, or blind One or more penetration flange.

flow paths with two SCIVs inoperable.

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 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 BFN-UNIT 3 3.6-48 Amendment No. 242, 294

SCIVs 3.6.4.2 This page intentionally left blank.

BFN-UNIT 3 3.6-49 Amendment No.~.~. 294

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Three SGT subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SGT subsystem A.1 Restore SGT subsystem 7 days 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 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 C. Two or three SGT C.1 Enter LCO 3.0.3. Immediately subsystems inoperable.

BFN-UNIT 3 3.6-51 Amendment No.~. 249, 294

SGT System 3.6.4.3 This page intentionally left blank.

BFN-UNIT 3 3.6-52 Amendment No. 242, 249, 294

SGT System 3.6.4.3 This page intentionally left blank.

BFN-UNIT 3 3.6-53 Amendment No.~. 249, 294

CREV System 3.7.3

3. 7 PLANT SYSTEMS 3.7.3 Control Room Emergency Ventilation (CREV) System LCO 3.7.3 Two CREV subsystems shall be OPERABLE.

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

The main control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREV subsystem A.1 Restore CREV subsystem 7 days inoperable for reasons to OPERABLE status.

other than Condition B, C, orD.

B. One or more CREV B.1 Initiate action to Immediately subsystems inoperable implement mitigating due to inoperable CRE actions boundary.

AND B.2 Verify mitigating actions 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months erisure CRE occupant exposures to radiological hazards will not exceed limits, and verify the CRE occupants are protected from smoke and chemical hazards.

AND B.3 Restore CRE boundary to 90 days OPERABLE status.

(continued)

BFN-UNIT 3 3.7-9 Amendment 244, ~ . ~ . ~ .

~.294

GREV System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two GREV subsystems C.1 Restore HEPA filter and 7 days inoperable due to one charcoal adsorber to inoperable High OPERABLE status.

Efficiency Particulate Air (HEPA) filter or charcoal adsorbers which do not impact ability of GREV subsystems to meet flowrate requirements specified in the Ventilation Filter Testing Program (VFTP).

D. One GREV subsystem D.1 Restore charcoal 14 days inoperable due to adsorber to OPERABLE inoperable charcoal status.

adsorber which does not impact the ability of GREV subsystem to meet flowrate requirements specified in the VFTP.

E. Required Action and E.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, B, AND C, or D not met.

E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Two CREV subsystems F.1 Enter LCO 3.0.3. Immediately inoperable for reasons other than Condition B or C.

BFN-UNIT 3 3.7-10 Amendment~.~.~.

~.294

CREV System 3.7.3 This page intentionally left blank.

BFN-UNIT 3 3.7-11 Amendment 24+, ~ . 26+,

2e7, 294

Control Room AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Two Unit 3 control room AC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE AL TERA TIONS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Unit 3 control room A.1 Restore Unit 3 control 30 days AC subsystem room AC subsystem to inoperable. OPERABLE status.

(continued)

BFN-UNIT 3 3.7-13 Amendment No.~. 294

Control Room AC System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 -------------NOTE-------------

associated Completion LCO 3.0.3 is not Time of Condition A or B applicable.

not met during movement of irradiated fuel assemblies in the Place OPERABLE control Immediately secondary containment or room AC subsystem in during CORE operation.

ALTERATIONS.

OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND 0.2.2 Suspend CORE Immediately ALTERATIONS.

BFN-UNIT 3 3.7-15 Amendment No. ~ . 294

AC Sources - Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to restore Immediately required offsite power circuit to OPERABLE status.

B. One or more required B.1 Suspend CORE Immediately Unit 3 DGs inoperable. ALTERATIONS.

AND B.2 Suspend movement of Immediately irradiated fuel assemblies in secondary containment.

AND B.3 Initiate action to restore Immediately required Unit 3 DGs to OPERABLE status.

(continued)

BFN-UNIT 3 3.8-16 Amendment No. 242, 294

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 --------------------------N()TE-------------------------

The following SRs are not required to be performe~: SR 3.8.1.2, SR 3.8.1.5, SR 3.8.1.7, and SR 3.8.1.8.

For Unit 3 AC sources required to be In accordance

()PERABLE, the SRs of Specification 3.8.1 with applicable are applicable, except for SR 3.8.1.6 and SR SRs 3.8.1.9.

SR 3.8.2.2 For the required Unit 1 and 2 DG, the SRs of In accordance Unit 1 and 2 Technical Specifications are with applicable applicable. SRs BFN-UNIT 3 3.8-18 Amendment No. ~ . 294

DC Sources - Shutdown 3.8.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to restore Immediately required DC electrical power subsystems or systems to OPERABLE status.

BFN-UNIT 3 3.8-27 Amendment No.~. 294

Distribution Systems - Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate actions to restore Immediately required AC and DC electrical power distribution subsystems to OPERABLE status.

A.2.4 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

BFN-UNIT 3 3.8-40 Amendment No.~. 294

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 311, 334, AND 294 TO RENEWED FACILITY OPERATING LICENSES NOS. DPR-33, DPR-52, AND DPR-68 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 DOCKET NOS. 50-259, 50-260, AND 50-296

1.0 INTRODUCTION

By application dated January 25, 2019 (Reference 1), as supplemented by letter dated August 8, 2019 (Reference 2), Tennessee Valley Authority (TVA, the licensee), requested to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" (Reference 3) which changes the Browns Ferry Nuclear Plant (Browns Ferry or BFN), Units 1, 2, and 3, Technical Specifications (TSs). The final safety evaluation (SE) for TSTF-542, Revision 2, was approved by the U.S. Nuclear Regulatory Commission (NRC, the Commission) on December 20, 2016 (Reference 4).

The proposed changes would replace existing TS requirements associated with "operations with a potential for draining the reactor vessel" (OPDRVs) with revised TSs, providing an alternative requirement for reactor pressure vessel (RPV) water inventory control (WIC). These alternative requirements would protect Safety Limit TS 2.1.1.3, which states, "Reactor vessel water level shall be greater than the top of active irradiated fuel."

Additionally, a new definition for "Drain Time" would be added to the Browns Ferry TS 1.1, "Definitions." The definition of Drain Time would establish requirements for the licensee to make RPV water level inventory determinations and to calculate RPV water inventory drain rates for Modes 4 and 5 outage-related activities. Adequate licensee management of secondary containment requirements or mitigation of certain emergency core cooling system (ECCS) safety injection/spray systems during Modes 4 and 5 requires an accurately calculated Drain Time.

The licensee has proposed variations from TSTF-542, Revision 2, or the NRG-approved TSTF-542 SE. These are explained in Section 2.2.6 and evaluated Section 3.5 of this SE.

The supplement dated August 8, 2019, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on May 7, 2019 (84 FR 19974).

Enclosure 4

2.0 REGULATORY EVALUATION

2.1 System Description Boiling water reactor (BWR) RPVs have a number of penetrations located below the top of active fuel (TAF). These penetrations provide entry for control rods, recirculation flow, reactor water cleanup (RWCU), and shutdown cooling. Since these penetrations are below the TAF, this creates a potential to drain the reactor vessel water inventory and lose effective core cooling. The loss of water inventory and effective core cooling can potentially lead to fuel cladding failure and radioactive release.

During operation in Modes 1 (Power Operation - Reactor Mode Switch in Run), 2 (Startup -

Reactor Mode Switch in Refuel 1 or Startup/Hot Standby), and 3 (Hot Shutdown 1 - Reactor Mode Switch in Shutdown and average reactor coolant temperature> 212 degrees Fahrenheit

(°F)), the TSs for instrumentation and ECCSs require operability of sufficient equipment to ensure large quantities of water will be injected into the vessel should the level decrease below the preselected value. These requirements are designed to mitigate the effects of a loss-of-coolant accident (LOCA), but also provide protection for other accidents and transients that involve a water inventory loss.

During BWR operation in Mode 4 (Cold Shutdown 1 - Reactor Mode Switch in Shutdown and average reactor coolant temperature s 212 °F) and Mode 5 (Refueling2 - Reactor Mode Switch in Shutdown or Refuel), the pressures and temperatures that could cause a significant mass and energy release due to the LOCA that would require an evaluation with respect to Title 1O of the Code of Federal Regulations (10 CFR) Section 50.46 are not present. During certain phases of refueling (Mode 5), a large volume of water is available above the RPV (i.e., the RPV head is removed). The water level is ~ 22 feet over the top of the RPV flange in accordance with TS 3.9.6, "Reactor Pressure Vessel (RPV) Water Level."

The large volume of water available in and above the RPV (during much of the time when in Mode 5) provides time for operator detection and manual operator action to stop and mitigate an RPV draining event. However, typically, at other times during a refueling outage during Cold Shutdown (Mode 4) or Refueling (Mode 5), there may be a potential for significant drainage paths from certain outage activities, human error, and other events when it is more likely to have some normally available equipment, instrumentation, and systems inoperable due to maintenance and outage activities. There may not be as much time for operator action as compared to times when there are large volumes of water above the RPV.

In comparison to Modes 1, 2, and 3 with typical high temperatures and pressures (especially in Modes 1 and 2), Modes 4 and 5 generally do not have the high pressure and temperature considered necessary for a LOCA envisioned from a high energy pipe failure. Thus, while the potential sudden loss of large volumes of water from a LOCA are not expected, operators monitor for BWR RPV water level decrease from potentially significant or unexpected drainage paths. These potential drainage paths in Modes 4 and 5 generally would require less water replacement capability to maintain water above TAF.

To address the draindown potential during Modes 4 and 5, the current Browns Ferry TSs contain specifications that are applicable during an OPDRV or require suspension of OPDRVs if All reactor vessel head closure bolts fully tensioned 2 One or more reactor vessel head closure bolts less than fully tensioned

certain equipment is inoperable. The term OPDRV is not specifically defined in the TSs and historically has been subject to inconsistent application by licensees. The changes discussed in this SE are intended to resolve any ambiguity by creating a new RPV WIC TS with attendant equipment operability requirements, required actions and surveillance requirements (SRs), and deleting references to OPDRVs throughout the TSs.

The standby alternating current (AC) supply and distribution system for Browns Ferry, Units 1 and 2, includes four diesel generators (DGs) (A, B, C, and D). The standby AC supply and distribution system for Unit 3 is separate from that for Units 1 and 2. It consists of four DGs (3A, 38, 3C, and 3D) that can be connected to 4 kilovolt (kV) shutdown boards. The standby AC supply and distribution systems are connected so that they supply unitized power to the Units 1, 2, and 3 electrical loads. Each of the DGs is assigned to one 4 kV shutdown board. For Units 1 and 2, the Updated Final Safety Analysis Report (UFSAR) states that it is possible through breaker ties to make any DG available to any 4 kV shutdown board. For flexibility of operation, provisions have been made using manually controlled circuit breakers for the interconnection of 4 kV shutdown boards of Units 1 and 2 with 4 kV shutdown board of Unit 3.

The ECCSs consist of the following:

high pressure coolant injection system (HPCI)

automatic depressurization system

core spray (CS) system

low pressure coolant injection system (LPCI), an operating mode of the residual heat removal (RHR) system The ECCS is designed to limit clad temperature over the complete spectrum of possible break sizes in the nuclear system process barrier, including the design-basis break. The design-basis break is defined as the complete and sudden circumferential rupture of the largest pipe connected to the reactor vessel (i.e., one of the recirculation loop pipelines) with displacement of the ends so that blowdown occurs from both ends.

During Modes 4 and 5, two ECCS subsystems (CS or LPCI) are required to be operable in accordance with existing TS 3.5.2.

2.2 Proposed TS Changes Section 2.2.1 describes the proposed addition of a new definition, "Drain Time" (evaluated in Section 3.1 of this SE).

Section 2.2.2 describes (1) the proposed revisions to TS 3.3, "Instrumentation," including the proposed revisions to TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation";

(2) the proposed addition of new TS 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" (including Table 3.3.5.2); and (3) proposed revisions to TS 3.3.6.1, "Primary Containment Isolation Instrumentation." These sections are evaluated in Sections 3.2 and 3.5.14 of this SE, respectively.

Section 2.2.3 describes the proposed revisions to TS 3.5, "Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling (RCIC) System," which includes the proposed revision to TS 3.5.2, "ECCS - Shutdown" (evaluated in Section 3.4 of this SE).

Section 2.2.4.1 describes the proposed deletion of existing TS references to OPDRVs (evaluated in Section 3.6 of this SE).

Section 2.2.6 describes Browns Ferry plant-specific variations to TSTF-542, Revision 2 (evaluated in Section 3.5 of this SE).

2.2.1 Addition of Drain Time Definition The following definition of "Drain Time" would be added to Section 1.1, "Definitions":

The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel {TAF) seated in the RPV assuming:

a. The water inventory above the TAF is divided by the limiting drain rate;

b. The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation devices without offsite power.

c. The penetration flow paths required to be evaluated per paragraph b are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;

d. No additional draining events occur; and

e. Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

2.2.2 TS 3.3, "Instrumentation" The following subsections describe the proposed changes to TS 3.3, "Instrumentation."

2.2.2.1 TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," and Table 3.3.5.1-1, "Emergency Core Cooling System (ECCS) Instrumentation Proposed changes to TS 3.3.5.1 include the deletion of Note 1 in Required Actions B.1, C.1, and E.1, which states:

Only applicable in MODES 1, 2, and 3.

As a result, the numbering for Note 2 would be removed with no change in that Note.

For TS Table 3.3.5.1-1, "Emergency Core Cooling System (ECCS) Instrumentation," the proposed changes delete the Applicability in Modes 4 and 5 because the instrumentation requirements during shutdown would be consolidated into the new TS 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation." Modes 4 and 5 Applicability and Associated Requirements would be deleted for the following TS Functions:

1. Core Spray System

a. Reactor Vessel Water Level - Low Low Low Level 1

c. Reactor Steam Dome Pressure - Low (Injection Permissive and ECCS Initiation)

d. Core Spray Pump Discharge Flow - Low (Bypass)

e. Core Spray Pump Start - Time Delay Relay [five Functions shown below]

Pumps A, B, C, D (with diesel power)

Pump A (with normal power)

Pump B (with normal power)

Pump C (with normal power)

Pump D (with normal power)

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Vessel Water Level - Low Low Low Level 1

c. Reactor Steam Dome Pressure - Low (Injection Permissive and ECCS Initiation

f. Low Pressure Coolant Injection Pump Start - Time Delay Relay [five Functions shown below]

Pumps A, B, C, D (with diesel power)

Pump A (with normal power)

Pump B (with normal power)

Pump C (with normal power)

Pump D (with normal power)

Table 3.3.5.1-1 Footnote (a), which states, "When the associated subsystem(s) are required to be OPERABLE," would be deleted.

2.2.2.2 New TS 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" The proposed new TS 3.3.5.2 would contain existing "ECCS and Primary Containment Isolation" instrumentation Functions that are relocated from TSs 3.3.5.1 and 3.3.6.1, as well as new requirements. The proposed new TS 3.3.5.2 is shown below:

3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Enter the Condition Immediately channels inoperable. referenced in Table 3.3.5.2-1 for the channel.

B. As required by B.1 Declare associated Immediately Required Action A.1 penetration flow path( s) and referenced in incapable of automatic Table 3.3.5.2-1. isolation.

AND B.2 Calculate DRAIN TIME. Immediately C. As required by C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Required Action A.1 and referenced in Table 3.3.5.2-1.

D. As required by D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Required Action A.1 OPERABLE status.

and referenced in Table 3.3.5.2-1.

E. Required Action and E.1 Declare associated low Immediately associated pressure Emergency Core Completion Time of Cooling System (ECCS)

Condition C or D not injection/spray subsystem met. inoperable.

SURVEILLANCE REQUIREMENTS

N()TE----------------------------------------------------

Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.3.5.2.2 Perform CHANNEL FUNCTl()NAL TEST. 92 days Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE C()NDITl()NS MODES REQUIRED REFERENCE OR OTHER CHANNELS DFROM SURVEILLANCE SPECIFIED PER REQUIRED REQUIREMENTS ALL()WABL FUNCTION CONDITIONS FUNCTION ACTl()N A.1 E VALUE

a. Core Spray System

a. Reactor 4,5 2 per trip C SR 3.3.5.2.1 s 465 psig Steam system <a> SR 3.3.5.2.2 Dome Pressure -

Low (Injection Permissive)

b. Core Spray 4, 5 1 per D SR 3.3.5.2.2 ~ 1647 gpm Pump subsystem <a> ands 2910 Discharge gpm Flow- Low (Bypass)

b. Low Pressure Coolant Injection (LPCI)

System

a. Reactor 4, 5 2 in one trip C SR 3.3.5.2.1 s 465 psig Steam system (a) SR 3.3.5.2.2 Dome Pressure -

Low (Injection Permissive)

C. Shutdown Cooling System Isolation

a. Reactor (b) 1 per trip B SR 3.3.5.2.1 ~ 528 Vessel system SR 3.3.5.2.2 inches above Water Level vessel zero

-Low, Level3

d. Reactor Water Cleanup (RWCU)

System Isolation

a. Reactor (b) 1 per trip B SR 3.3.5.2.1 ~ 528 Vessel system SR 3.3.5.2.2 inches Water Level above vessel

-Low, zero Level3 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control."

(b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

2.2.2.3 TS 3.3.6.1, "Primary Containment Isolation Instrumentation" In TS Table 3.3.6.1-1, Function 6.b, Shutdown Cooling System Isolation, Reactor Vessel Water Level - Low, Level 3, the Applicability in Modes 4 and 5 will be deleted. Also, Footnote (b) to Table 3.3.6.1-1 will be deleted, as it is applicable only to Function 6.b during Modes 4 and 5.

This Function would be moved to the new TS Table 3.3.5.2-1 Function 3.a, as shown in Section 2.2.2.2 of this SE.

In TS LCO 3.3.6.1, Required Action 1.2 will be deleted since it is associated with the isolation of RHR shutdown cooling system during Modes 4 and 5.

2.2.3 TS 3.5, "Emergency Core Cooling System {ECCS) and Reactor Core Isolation Cooling (RCIC) System" The title of TS 3.5 would be revised from "Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling (RCIC) System" to "Emergency Core Cooling Systems (ECCS),

RPV Water Inventory Control, and Reactor Core Isolation Cooling (RCIC) System."

The title of TS 3.5.2 would be revised from "ECCS - Shutdown" to "Reactor Pressure Vessel (RPV) Water Inventory Control." Also, TS 3.5.2 would be revised as follows:

LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND One low pressure ECCS injection/spray subsystem shall be OPERABLE.

1\l()l"E:---------------------------------------

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPE:RABLE: during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILllY: MODE:S 4 and 5.

AC"TIOI\IS COI\IDl"TIOI\I RE:QUIRE:D AC"TIOI\I C()MPLE:1"101\1 "TIME:

A. Required E:CCS A.1 Restore required E:CCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray subsystem injection/spray subsystem to inoperable. ()PE:RABLE: status.

B. Required Action and B.1 Initiate action to establish a Immediately associated Completion method of water injection capable "Time of Condition A not of operating without offsite met. electrical power.

C. DRAII\I "TIME:< 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.1 Verify secondary containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and ~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . boundary is capable of being established in less than the DRAII\I "TIME AI\ID C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAII\I "TIME AI\ID C.3 Verify two standby gas treatment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months subsystems are capable of being placed in operation in less than the DRAII\I "TIME D. DRAII\I "TIME: < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.1 --------------I\IO"TE:------------

Required E:CCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an Immediately additional method of water injection with water sources

capable of maintaining RPV water level > TAF for ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to establish Immediately secondary containment boundary.

AND D.3 Initiate action to isolate each Immediately secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

AND D.4 Initiate action to verify two Immediately standby gas treatment subsystems are capable of being placed in operation.

E. Required Action and E.1 Initiate action to restore DRAIN Immediately associated Completion TIME to~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The proposed SRs for TS 3.5.2 are shown below (evaluated in Section 3.3.1 of this SE):

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.5.2.2 Verify, for the required ECCS injection/spray 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months subsystem, the suppression pool water level is

~ - 6.25 inches with or -7.25 inches without differential pressure control.

SR 3.5.2.3 Verify, for the required ECCS injection/spray 31 days subsystem, the piping is filled with water from the pump discharge valve to the injection valve.

SR 3.5.2.4 Verify, for the required ECCS injection/spray 31 days subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.2.5 Operate the required ECCS injection/spray 92 days subsystem through the test return line for

~ 10 minutes.

SR 3.5.2.6 Verify each valve credited for automatically isolating a 24 months penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

SR 3.5.2.7 ---------------------J\l()l"E--------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem 24 months can be manually operated.

2.2.4 Deletion of Reference to ()PDRVs l"erm and Miscellaneous Change 2.2.4.1 Deletion of References to ()PDRVs In Reference 1, the licensee proposed to delete references to OPDRVs (or terms related to

()PDRVs) throughout the Browns Ferry l"Ss because they (1) contain one or more OPDRVs references, such as the conditional Applicability "during operations with a potential for draining the reactor vessel (OPDRVs)," or (2) if certain conditions are not met, the required actions direct the licensee to "initiate action to suspend operations with a potential for draining the reactor vessel (OPDRVs)." l"he following table lists these l"Ss and their affected sections.

Browns Ferry LC() Location of OPDRVs Reference 3.3.6.1, Primary Containment Isolation "fable 3.3.6.1-1 Footnote (b)

Instrumentation 3.3.6.2, Secondary Containment Isolation "fable 3.3.6.2-1 Footnote (a)

Instrumentation 3.3.7.1, Control Room Emergency "fable 3.3.7.1-1 Footnote (a)

Ventilation (CREV) System Isolation Instrumentation See Section 2.2.5.11 of this SE (Variation 11) 3.6.1.3, Primary Containment Isolation Applicability, Condition F Valves (PCIVs)

"MODES 1, 2, and 3" is removed from l"S 3.6.1.3, J\lote 4, and Condition E See Sections 2.2.6.14 and 2.2.6.15 of this SE (Variations 14 and 15, respectively)

3.6.4.1, Secondary Containment Applicability, Condition C "MODES 1, 2, and 3" is removed from TS 3.6.4.1, Condition A See Section 2.2.6.16 of this SE (Variation 16) 3.6.4.2, Secondary Containment Isolation Applicability, Condition D Valves (SCIVs)

"MODES 1, 2, and 3" is removed from TS 3.6.4.2, Condition C See Section 2.2.6.16 of this SE (Variation 16) 3.6.4.3, Standby Gas Treatment (SGT) Applicability, Conditions C and E System "MODES 1, 2, and 3" is removed from TS 3.6.4.2, Conditions B and D Condition D is renumbered as Condition C See Section 2.2.6.16 of this SE (Variation 16) 3.7.3, Control Room Emergency Ventilation Applicability, Conditions F and H

( CREV) System "MODES 1, 2, and 3" is removed from TS 3.7.3, Conditions B, E, and G Condition G is renumbered as Condition F See Section 2.2.6.16 of this SE (Variation 16) 3.7.4, Control Room Air Conditioning (AC) Applicability, Condition D Svstem 3.8.2, AC Sources - Shutdown Conditions A and B Existing Required Action A.2.4 is renumbered as A.2.3 Existing Required Action B.1.1, B 1.2, B.1.4 are renumbered as B.1, B.2, and B.3, respectively 3.8.5, DC Sources - Shutdown Condition A Existing Required Action A.2.4 is renumbered as A.2.3 3.8.8, Distribution Systems - Shutdown Condition A Existing Required Actions A.2.4 and A.2.5 are renumbered as A.2.3 and A.2.4, respectively 2.2.5 Miscellaneous Change, SR 3.8.2.1 SR 3.8.2.1 is changed to reflect a TS Note and exclusions. This is further described in Section 2.2.6.9 (Variation 9) and evaluated in Section 3.5.9 of this SE.

2.2.5.1 Miscellaneous Change, SR 3.8.2.1, Units 1 and 2 In Reference 1, the licensee proposed to modify SR 3.8.2.1, Units 1 and 2, which presently states:

SURVEILLANCE FREQUENCY SR 3.8.2.1 ---------------------N()l"E--------------------------

l"he following SRs are not required to be performed: SR 3.8.1.2, SR 3.8.1.5, SR 3.8.1.7, SR 3.8.1.8, and SR 3.8.1.9.

For Unit 1 and 2 AC sources required to be In accordance with the

()PERABLE, the SRs of Specifications 3.8.1, applicable SRs are applicable.

l"he proposed SR 3.8.2.1, Units 1 and 2, is shown below. SR 3.8.1.8 is removed from the Note and exceptions are added related to SRs 3.8.1.6 and 3.8.1.9.

SURVEILLANCE FREQUENCY SR 3.8.2.1 ---------------------N()l"E--------------------------

l"he following SRs are not required to be performed: SR 3.8.1.2, SR 3.8.1.5, SR 3.8.1.7, and SR 3.8.1.8.

For Unit 1 and 2 AC sources required to be In accordance with the

()PERABLE, the SRs of Specifications 3.8.1, applicable SRs are applicable, except SR 3.8.1.6 and SR 3.8.1.9.

2.2.5.2 Miscellaneous Change, SR 3.8.2.1, Unit 3 In Reference 1, the licensee proposed to modify SR 3.8.2.1, Unit 3, which presently states:

SURVEILLANCE FREQUENCY SR 3.8.2.1 ---------------------N()l"E--------------------------

l"he following SRs are not required to be performed: SR 3.8.1.2, SR 3.8.1.5, SR 3.8.1.7, SR 3.8.1.8, and SR 3.8.1.9.

For Unit 3 AC sources required to be In accordance with the

()PERABLE, the SRs of Specification 3.8.1, applicable SRs are applicable.

l"he proposed SR 3.8.2.1, Unit 3, is shown below. SR 3.8.1.8 is removed from the Note and exceptions are added related to SRs 3.8.1.6 and 3.8.1.9.

SR 3.8.2.1 ---------------------1\l()l"E--------------------------

l"he following SRs are not required to be performed: SR 3.8.1.2, SR 3.8.1.5, SR 3.8.1. 7, and SR 3.8.1.8.

For Unit 3 AC sources required to be In accordance with the

()PERABLE, the SRs of Specifications 3.8.1 applicable SRs are applicable, except SR 3.8.1.6 and SR 3.8.1.9.

2.2.6 Browns Ferry Plant-Specific l"Sl"F-542 Variations In Attachment 1, Section 2.2 of Reference 1, the licensee identified several Browns Ferry plant-specific l"S variations from l"Sl"F-542, Revision 2 (Reference 3), or the !\I RC-approved l"Sl"F-542 SE (Reference 4). l"he licensee stated these variations do not affect the Applicability of l"Sl"F-542 or the I\IRC staff's SE to the proposed license amendments. See Section 3.5 of this SE, which includes the I\IRC staff's evaluation for each variation.

2.2.6.1 Variation 1, l"able 3.3.5.1-1, Function 1.e, Core Spray Pump Start - l"ime Delay Relay Standard l"echnical Specifications (Sl"S), I\IUREG-1433 (Reference 6 and Reference 7) does not have a requirement for "Core Spray Pump Start - l"ime Delay Relay: found in the Browns Ferry l"S l"able 3.3.5.1-1, Function 1.e. However, this Function is similar to l"S l"able 3.3.5.1-1, Function 2.f, for "LPCI Pump Start - l"ime Delay Relay" that was deleted by l"Sl"F-542 and not relocated to new "fable 3.3.5.2 because ECC~ pump auto-starts on the DGs are no longer required. Accordingly, it is appropriate to delete this Function for CS from the Browns Ferry l"Ss, Modes 4 and 5.

2.2.6.2 Variation 2, Manual Initiation of ECCS Injection/Spray l"here are Sl"S (Reference 6 and Reference 7) requirements on which l"Sl"F-542 is based related to 'manual initiation' that do not appear in the Browns Ferry l"Ss. Sl"S "fable 3.3.5.1-1 contains Functions 1.e and 2.h, Manual Initiation, for CS and LPCI, respectively. l"he 'manual initiation' logic does not exist in the Browns Ferry design. l"herefore, "fable 3.3.5.2-1, Functions 1.c and 2.c, as well as the related l"Sl"F-542 SR 3.3.5.2.3 and SR 3.5.2.8, db not apply to Browns Ferry. As an alternative, the licensee proposes that l"S 3.5.2 include SR 3.5.2. 7 to verify that the Browns Ferry required ECCS injection/spray subsystem can be manually operated.

2.2.6.3 Variation 3, l"able 3.3.5.2-1, Function 1.d, Core Spray Pump Discharge Flow - Low (Bypass) l"Sl"F-542 l"able 3.3.5.2-1, Function 1.d., Core Spray Pump Discharge Flow - Low (Bypass),

specifies the inclusion of SR 3.3.5.1.1, "Perform Channel Check." Browns Ferry does not have the capability to perform a channel check for analogous "fable 3.3.5.2-1, Function 1.b., and this is not a current requirement in Browns Ferry l"S "fable 3.3.5.1-1. Accordingly, no channel check is proposed for this Function.

2.2.6.4 Variation 4, Table 3.3.5.1-1, Function 2.c, LPCI System Reactor Steam Dome Pressure - Low (Injection Permissive and ECCS Initiation),

Browns Ferry TS Table 3.3.5.1-1, Function 2.c, LPCI System Reactor Steam Dome Pressure -

Low (Injection Permissive and ECCS Initiation), specifies four required channels per Function (RCPF). This correlates to two channels in Trip System A (powered by Division I) and two channels in Trip System B (powered by Division II), which are configured in series with a cross-connect between the divisional output contacts. Since outage planning and scheduling is typically based around 'protected' divisions, it follows that either Trip System A or B may be unavailable. Trip capability is maintained by the other trip system in a two-out-of-two trip logic for each LPCI injection valve. Consistent with single failure not being applicable for RPV WIC, only two channels in one trip system are required to be operable for Browns Ferry Table 3.3.5.2-1, Function 2.a.

2.2.6.5 Variation 5, Table 3.3.5.1-1, Function 2.g, LPCI Pump Discharge Flow- Low (Bypass)

STS Table 3.3.5.1-1, Function 2.g, LPCI Pump Discharge Flow - Low (Bypass), does not exist in the Browns Ferry TSs. This is because the RHR minimum flow valve is open when in the standby configuration and is sized such that the LPCI subsystem remains operable, even with the valve fully open. Accordingly, the analogous STS Table 3.3.5.2-1, Function 2.b, LPCI Pump Discharge Flow - Low, Bypass, has not been added to new Browns Ferry Table 3.3.5.2-1.

2.2.6.6 Variation 6, Table 3.3.5.2-1, Function 3.a, Shutdown Cooling System Isolation - Reactor Vessel Water Level - Low, Level 3, and Function 4.a, RWCU System Isolation - Reactor Vessel Water Level - Low, Level 3 STS Table 3.3.6.1-1, Function 6.b, Shutdown Cooling System Isolation - Reactor Vessel Water Level - Low, Level 3, designates two required channels in one trip system in Modes 4 and 5.

This was transferred to new Table 3.3.5.2-1, Function 3.a, with two required channels in one trip system. As described in the STS 3.3.6.1 Bases Background for Function 6, four reactor water level channels input to two two-out-of-two trip systems with each of the two trip systems associated with one of the two valves on each shutdown cooling penetration. Thus, two channels are required in one trip system to ensure either the inboard or outboard isolation valve closes on a valid signal.

The logic design for Browns Ferry is different from the NUREG-1433 reference plant. The Browns Ferry logic is four channels arranged with two channels in Trip System A and two channels in Trip System B. They are arranged in a one-out-of-two-taken twice logic, which isolates both the inboard and outboard isolation valves. Thus, for new Table 3.3.5.2-1, Function 3.a, one required channel per trip system is specified. This is consistent with the existing requirements in Table 3.3.6.1-1, Footnote (b). The closure logic is the same for the RWCU isolation valves. Therefore, new Table 3.3.5.2-1, Function 4.a, similarly specifies one required channel per trip system.

2.2.6.7 Variation 7, Secondary Containment Design, and TS 3.5.2, Required Actions C.3 and D.4, Standby Gas Treatment Subsystems The primary containment systems and essentially all of the ECCSs for the three reactors are located inside the bounds of the secondary containment system. The reactor building

substructure consists of poured-in-place reinforced concrete exterior walls that extend up to the refueling floor. The refueling room floor is also made of reinforced poured-in-place concrete.

The superstructure of the reactor building above the refueling floor is a structural steel frame.

This frame supports the roof decking and the overhead crane tracks, as well as the foamwall stepped fascia panels and the insulated metal siding panels. The built-up roof, the stepped fascia panels, and the metal siding form the secondary containment membrane above the refueling floor.

Browns Ferry is designed with three subsystems of standby gas treatment (SGT} servicing all three units. A minimum of two subsystems of SGT are required to keep the three reactor building zones and the common refueling zone at the required negative pressure. In contrast, the reference plant for NUREG-1433 requires only a single standby SGT system subsystem to maintain secondary containment at negative pressure. The Browns Ferry SGT system is further described in UFSAR Section 5.3.3.7, which states, in part:

The basic system consists of a suction duct system, three filter trains and blowers, and a discharge vent system. The suction duct system exhausts from the normal ventilation exhaust duct of each of the three reactor zones ahead of the isolation valves and from the refueling zone independent of the normal ventilation system.

Accordingly, a variation is taken for new TS 3.5.2, Required Action C.3, to require verification that two SGT subsystems are capable of being placed in operation in less than the Drain Time, instead of a single SGT subsystem. Similarly, new Required Action D.4 will initiate action to establish two SGT subsystems are capable of being placed in operation instead of a single SGT subsystem.

2.2.6.8 Variation 8, Shared Common Refueling Floor and Shared SGT Subsystems, TS 3.5.2, Required Action D.3 TSTF-542, TS 3.5.2 Required Actions C.1, C.2, C.3, D.2, D.3, and D.4, are premised on the assumption that secondary containment has been relaxed. Browns Ferry, Units 1, 2, and 3, have a common refueling floor and shared SGT subsystems. This results in secondary containment rarely being relaxed (i.e., secondary containment, the SCIVs, and the SGT system are maintained operable per an online unit's TSs. Specifically, Required Action D.3 is changed to allow crediting 'automatic' isolation of each secondary containment penetration flow path as an alternative to a manual isolation from the control room.

2.2.6.9 Variation 9, TS 3.8.2, AC Sources - Shutdown, SR 3.8.2.1 Note and SR Exceptions Browns Ferry, Units 1 and 2, SR 3.8.2.1 requires that for the Units 1 and 2 AC sources required to be operable, the SRs of TS 3.8.1 are applicable. This SR is modified by a Note that excludes certain SRs from the AC sources operating TSs. It is the intent that these excluded SRs*must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit are required to be operable.

However, with the adoption of TSTF-542, there is no longer a need for a DG auto-start on an accident signal in Modes 4 and 5. Accordingly, SR 3.8.1.9, "Verify, on an actual or simulated

loss-of-offsite power (LOOP) signal in conjunction with an actual or simulated ECCS initiation signal. .. ," may be removed from the SR 3.8.2.1 Note and listed as an exception to this SR.

Similarly, SR 3.8.1.6, "Verify on an actual or simulated accident signal each DG auto-starts from standby condition," is no longer necessary and may be included as an exception to SR 3.8.2.1.

Changes are also made to Browns Ferry, Unit 3, SR 3.8.2.1, related to the Unit 3 AC sources required to be operable.

2.2.6.10 Variation 10, Surveillance Frequencies Browns Ferry contains several new SRs with frequencies that are designated as site-specific and different from the STS and TSTF-542.

SR 3.3.5.2.1 Perform CHANNEL CHECK.

The STS have this frequency as [12] hours; Browns Ferry proposed this SR with a frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SR 3.5.2.6 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolated signal.

TSTF-542 has this frequency as [18] months; Browns Ferry proposed changing to a frequency of 24 months.

SR 3.5.2.7 Verify the ECCS injection/spray subsystem can be manually operated.

TSTF-542 has this frequency as [18] months; Brows Ferry proposed this SR with a frequency of 24 months.

2.2.6.11 Variation 11, Table 3.3. 7.1-1, Control Room Emergency Ventilation System Instrumentation, Footnote (a)

TSTF-542 removes Footnote (a), "During operations with a potential for draining the reactor vessel," from Table 3.3.7.1-1, Function 4, "Refueling Floor Area Radiation - High," and Function 5, "Control Room Air Inlet Radiation - High." The Browns Ferry design does not have refueling floor area radiation monitors that actuate the control room emergency ventilation (CREV) system. Instead, the Browns Ferry design has Function 3, "Reactor Zone Exhaust Radiation - High," and Function 4, "Refueling Floor Exhaust Radiation - High," which provide the CREV system actuation with the identical footnote. Therefore, Footnote (a) is removed from Table 3.3.7.1-1.

2.2.6.12 Variation 12, LCO 3.5.2 Note, Alignment, and Operation for Decay Heat Removal In NUREG-1433, LCO 3.5.2 is modified by a Note regarding the low-pressure coolant injection subsystem being considered operable during alignment and operation for decay heat removal.

This Note is modified by TSTF-542 to change 'one' to 'a.' In the Browns Ferry TSs, this Note modifies new SR 3.5.2.4 (rather than the LCO). The verbiage is the same between the Browns

Ferry TSs and NUREG-1433, but the location of the Note in NUREG-1433 was changed from the SR to the LCO as a result of TSTF-416, "SR 3.5.1.2" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML012390252). To maintain consistency with the presentation in TSTF-542, the SR 3.5.2.4 Note is being deleted from the SR and moved to LCO 3.5.2 at the LCO level.

2.2.6.13 Variation 13, Proposed New SR 3.5.2.5, ECCS Injection/Spray Subsystem Testing TSTF-542 establishes new SR 3.5.2.6 as "Operate the required ECCS injection/spray subsystem through the recirculation line for .!:: 10 minutes." The term 'recirculation line' is replaced with 'test return line' in new SR 3.5.2.5. This is the proper Browns Ferry terminology and is changed to avoid confusion with the reactor recirculation piping.

2.2.6.14 Variation 14, TS 3.6.1.3, Primary Containment Isolation Valves (PC IVs),

Applicability, Note 4, Condition E Browns Ferry TS 3.6.1.3 contains the following Applicability in addition to Modes 1, 2, and 3:

When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation."

However, with the removal of Modes 4 and 5 Applicability for Table 3.3.6.1-1, Function 6.b, "Shutdown Cooling System Isolation - Reactor Vessel Water Level - Low, Level 3," this table no longer contains any other applicable modes designated besides Modes 1, 2, or 3. Accordingly, the TS 3.6.1.3 Applicability is revised to delete the above sentence referencing LCO 3.3.6.1.

Additionally, since the only Applicability for TS 3.6.1.3 will be Modes 1, 2, and 3, it is not necessary to reiterate these modes in action Note 4 and Condition E; therefore, references to Modes 1, 2, and 3 are being deleted.

2.2.6.15 Variation 15, TS 3.6.1.3, Primary Containment Isolation Valves (PC IVs), Condition F Browns Ferry TS 3.6.1.3, Condition F, states:

Required Action and associated Completion Time of Condition A, B, C, or D not met for PCIV(s) required to be OPERABLE during MODE 4 or 5.

This condition is analogous to STS 3.6.1.3, Condition H, as revised by TSTF-542 (except without the reference to OPDRVs ). However, with the removal of Modes 4 and 5 Applicability for Table 3.3.6.1-1, Function 6.b, "Shutdown Cooling System Isolation - Reactor Vessel Water Level - Low, Level 3," there are no longer any PCIV operability requirements when in Modes 4 or 5. Accordingly, the entire condition, required action, and Completion Time (CT) are being removed (versus just the references to OPDRVs in TSTF-542), as these items are no longer applicable.

2.2.6.16 Variation 16, Removal of "MODE 1, 2 and 3" from Secondary Containment, SCIVs, SGT, and CREV TSs Consistent with TSTF-542, Revision 2, the licensee is proposing to delete "During operations with a potential for draining the reactor vessel (OPDRVs)" from the Applicability. Thus, the remaining Applicability is Modes 1, 2, and 3. The following conditions contain the phrase "in

MODE 1, 2, or 3." This phrase is proposed to be deleted as it is no longer needed for the following TSs:

TS 3.6.4.1, Condition A TS 3.6.4.2, Condition C TS 3.6.4.3, Conditions Band C (new)

TS 3.7.3, Conditions B, E, and F (new) 2.2.6.17 Variation 17, Preferred Pump Logic (Browns Ferry), Units 1 and 2, only)

This variation was provided by the licensee in Reference 2 since Browns Ferry has a unique instrumentation and controls for the electrical design at this three-unit station.

Browns Ferry UFSAR Section 6.4.3, Core Spray (CS) System, states:

For Units 1 and 2, a Core Spray signal will initiate the ECCS preferred pump logic to trip any running RHR and Core Spray pumps in the opposite unit. In the event of a LOCA in conjunction with a spurious accident signal from the opposite unit, the ECCS preferred pump logic will dedicate the Division I pump (1A and 1C) to Unit 1 and the Division II pumps (28 and 20) to Unit 2. This will ensure that the shared Unit 1/2 4KV shutdown boards are not overloaded in the event of a real and spurious accident signal.

Browns Ferry UFSAR Section 6.4.4, Low Pressure Coolant Injection System (LPCI), states:

For Units 1 and 2, a RHR (LPCI) signal will initiate the ECCS preferred pump logic to trip any running RHR and Core Spray pumps in the opposite unit. In the event of a LOCA in conjunction with a spurious accident signal from the opposite unit, the ECCS preferred pump logic will dedicate the Division I pump ( 1A and 1C) to Unit 1 and the Division II pumps (28 and 20) to Unit 2. This will ensure that the shared Unit 1/2 4KV shutdown boards are not overloaded in the event of a real and spurious accident signal.

The Preferred Pump Logic (PPL) is associated with Browns Ferry, Units 1 and 2; Unit 3 is unaffected. If there is a LOCA involving Unit 1, the PPL will trip any operating low pressure ECCS pumps in Unit 2. Similarly, if the LOCA involves Unit 2, the PPL will trip any operating low pressure ECCS pumps in Unit 1. In addition, manual start of the low pressure ECCS pumps (credited in proposed TS 3.5.2) in the non-accident unit is inhibited for a 60-second time delay period. After this time delay, a manual low pressure ECCS pump start can be accomplished, subject to the electrical load on the Units 1 and 2 4 kV shutdown boards from the accident unit.

The operation of PPL is identical, whether there is a LOCA coincident with a LOOP or a LOCA with offsite power available.

2.2.6.18 Variation 18, Common Accident Signal (Units 1, 2, and 3)

This variation was provided by the licensee in Reference 2 since Browns Ferry has unique instrumentation and controls for the electrical design at this three-unit station.

The purpose of Common Accident Signal (CAS) is to ensure that the shared Units 1 and 2 4 kV shutdown boards are stripped prior to starting the RHR pumps, CS pumps, and other required loads when the shutdown boards are being supplied by the DGs.

Browns Ferry UFSAR Section 7.4.3.4.7, "Core Spray System and Accident Signal Initiation,"

states, in part, that the low reactor vessel water level or high drywell pressure coincident with low reactor pressure signals is also used to generate a CAS, which affects the operation of components associated with all three units.

The current licensing basis for the Browns Ferry site is that if there is a LOCA coincident with a LOOP in one unit, offsite power is assumed to be lost for the non-accident units as well. For a non-accident Unit in Mode 4 or 5, power for the low pressure ECCS subsystem (credited in proposed TS 3.5.2) will be restored when the associated DGs reenergize the unit's 4 kV shutdown board.

2.2.6.19 Variation 19, Unit Priority Re-Trip Logic (Units 1, 2, and 3)

This variation was provided by the licensee in Reference 2 since Browns Ferry has a unique instrumentation and controls for the electrical design at this three-unit station.

The purpose of Unit Priority Re-trip Logics is to ensure that the shared Units 1 and 2 4 kV shutdown boards are stripped prior to starting the RHR pumps, CS, and other required loads when the shutdown boards are being supplied by the DGs.

Browns Ferry UFSAR Section 7.4.3.4.7 states, in part, that following an initiation of a CAS on either Units 1, 2, or 3 (which trips all eight diesel breakers), subsequent accident signal trips of the diesel breakers are blocked. A second diesel breaker trip on a 'unit priority' basis is provided to ensure that during combinations of spurious and real accident signals, the diesel supplied buses are stripped prior to starting the RHR pumps and other ECCS loads. This diesel breaker re-trip will only occur if a spurious accident signal or a real accident signal from the other unit has previously tripped the diesel breakers.

Inputs from the RHR initiation circuitry indicating low reactor vessel water level or high drywell pressure coincident with low reactor pressure combined with an existing CAS trip signal will re-trip the diesel breakers on the unit where the RHR initiation signal originated. The other unit's diesels will be unaffected by this second trip. Thus, each unit is given priority over the block of subsequent CAS diesel breaker trips for its diesels. This diesel breaker 'unit priority re-trip' ensures that the diesel buses are stripped prior to starting the RHR pumps, CS pumps, and other required loads.

The current licensing basis for the Browns Ferry site assumes a LOCA coincident with a LOOP in one unit with a concurrent LOOP event for the non-accident units. For a non-accident unit in Mode 4 or 5, power for the low pressure ECCS subsystem will be restored when the associated DGs reenergize the Unit 4 kV shutdown board. As a defense-in depth measure, DGs from Unit 3 can be connected to the accident unit or the non-accident unit buses.

2.3 Applicable Regulatory Requirements and Guidance The regulation in 10 CFR 50.36(a)(1) requires an applicant for an operating license to include in the application proposed TSs in accordance with the requirements of 10 CFR 50.36.

As required by 10 CFR 50.36(c), TSs will include, among other things:

( 1) Safety limits, limiting safety system settings, and limiting control settings.

(i)(A) Safety limits for nuclear reactors are limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the physical barriers that guard against the uncontrolled release of radioactivity. If any safety limit is exceeded, the reactor must be shut down.

The licensee shall notify the Commission, review the matter, and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude recurrence. Operation must not be resumed until authorized by the Commission.

As required by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.

The regulation in 10 CFR 50.36(c)(3) requires TSs to include items in the category of SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs wiU be met.

Pursuant to 10 CFR 50.90, whenever a holder of an operating license desires to amend the license, application for an amendment must be filed with the Commission fully describing the changes desired, and following, as far as applicable, the form prescribed for original applications. The technical information to be included in an application for an operating license is governed in particular by 10 CFR 50.34(b).

As described in 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. The general considerations that guide the Commission include, as stated in 10 CFR 50.40(a), that the TSs provide reasonable assurance that the health and safety of the public will not be endangered. Also, to issue an operating license, of which TSs are a part, the Commission must make the findings in 10 CFR 50.57, including the 10 CFR 50.57(a)(3)(i) finding that there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public.

The NRC staff's guidance for review of TSs is in Chapter 16, "Technical Specifications," of NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" (SRP), dated March 2010 (Reference 5).

Volumes 1 and 2 of NUREG-1433, Revision 4 (Reference 6 and Reference 7), contain the STSs for BWR/4 plants; 3 and are part of the regulatory standardization effort. The NRC staff has prepared STSs for each of the light-water reactor nuclear designs.

2.3.1 Browns Ferry Applicable Regulatory Design Requirements Browns Ferry UFSAR, Appendix A, "Conformance to AEC Proposed General Design Criteria,"

describes an evaluation of the proposed general design criteria (GDC) (issued November 1965 (Units 1 and 2)) and July 1967 (Unit 3), which were used by the Atomic Energy Commission to evaluate the original design of the Browns Ferry station.

The following criteria from the Browns Ferry UFSAR are related to this license amendment request (LAR):

Criterion 9 - "Reactor Coolant Pressure Boundary." The reactor coolant pressure boundary shall be designed and constructed so as to have an exceedingly low probability of gross rupture or significant leakage throughout its design lifetime.

Criterion 12 - "Instrumentation and Control Systems." Instrumentation and controls shall be provided as required to monitor and maintain variables within prescribed operating ranges.

Criterion 13- "Fission Process Monitors and Controls." Means shall be provided for monitoring and maintaining control over the fission process throughout core life and for all conditions that can be reasonably anticipated to cause variations in reactivity of the core, such as indication of position of control rods and concentration of soluble reactivity control poisons.

Criterion 16 - "Monitoring Reactor Coolant Pressure Boundary." Means shall be provided for monitoring the reactor coolant pressure boundary to detect leakage.

Criterion 33- "Reactor Coolant Pressure Boundary Capability." The reactor coolant pressure boundary shall be capable of accommodating without rupture, and with only limited allowance for energy absorption through plastic deformation, the static and dynamic loads imposed on any boundary component as a result of any inadvertent and sudden release of energy to the coolant. As a design reference, this sudden release shall be taken as that which would result from a sudden reactivity insertion such as a rod ejection (unless prevented by positive mechanical means), rod dropout, or cold-water addition.

Criterion 37 - "Engineered Safety Features Basis for Design." Engineered safety features shall be provided in the facility to back up the safety provided by the core design, the reactor coolant pressure boundary, and their protection systems. As a minimum, such engineered safety features shall be designed to cope with any size reactor coolant pressure boundary break up to and including the circumferential rupture of any pipe in that boundary assuming unobstructed discharge from both ends.

Criterion 39 - "Emergency Power for Engineered Safety Features (Category A)." Alternate power systems shall be provided and designed with adequate independency, redundancy, capacity, and testability to permit the functioning required of the engineered safety features. As a minimum, the onsite power system and the offsite power system shall each, independently, provide this capacity, assuming a failure of a single active component in each power system.

3 Browns Ferry, Units 1, 2, and 3 are BWR/4 Mark 1 designs and have adopted the improved STS (BWR/4 ).

Criterion 41 - "Engineered Safety Features Performance Capability." Engineered safety features such as emergency core cooling and containment heat removal systems shall provide sufficient performance capability to accommodate partial loss of installed capacity and still fulfill the required safety function. As a minimum, each engineered safety feature shall provide this required safety function assuming a failure of a single active component.

Criterion 44- "Emergency Core Cooling System Capability." At least two ECCs, preferably of different design principles, each with a capability for accomplishing abundant emergency core cooling, shall be provided. Each ECCS and the core shall be designed to prevent fuel and clad damage that would interfere with the emergency core cooling function and to limit the clad metal-water reaction to negligible amounts for all sizes of breaks in the reactor coolant pressure boundary, including the double-ended rupture of the largest pipe. The performance of each ECCS shall be evaluated conservatively in each area of uncertainty. The systems shall not share active components and shall not share other features or components unless it can be demonstrated that (a) the capability of the shared feature or component to perform its required function can be readily ascertained during reactor operation, (b) failure of the shared feature or component does not initiate a LOCA, and (c) capability of the shared feature or component to perform its required function is not impaired by the effects of a LOCA and is not lost during the entire period this function is required following the accident.

3.0 TECHNICAL EVALUATION

Section 2.2 of this SE lists proposed TS changes, as included in Reference 1 and Reference 2, for the licensee to adopt TSTF-542, Revision 2. The following sections summarize the NRC staff's evaluation of each of these proposed changes.

3.1 Staff Evaluation of Proposed Drain Time Definition As discussed in Section 2.2.1 of this SE, the "Drain Time" is the time it would take the RPV water inventory to drain from the current level to the TAF, assuming the most limiting of the RPV penetrations flow paths with the largest flow rate or a combination of penetration flow paths that could open due to a common mode failure, were to open and the licensee took no mitigating action.

The NRC staff reviewed the proposed Drain Time definition from TSTF-542. For the purpose of NRC staff considerations, the term 'break' describes a pathway for water to drain from the RPV that has not been prescribed in the Drain Time definition in TSTF-542. Based on information furnished by the licensee, the NRC staff has determined that the licensee is appropriately adopting the principles of Drain Time as specified in TSTF-542.

The NRC has reasonable assurance that the licensee will include all RPV penetrations below the TAF in the determination of Drain Time as potential pathways. As part of this evaluation, the staff reviewed requests for additional information used during the development of TSTF-542, Revision 2, which provided examples of bounding Drain Time calculations for three examples:

(1) water level at or below the RPV flange, (2) water level above RPV flange with fuel pool gates installed, and (3) water level above RPV flange with fuel pool gates removed. The Drain Time is calculated by taking the water inventory above the break and dividing by the limiting drain rate until the TAF is reached. The limiting drain rate is a variable parameter depending on the break size and the reduction of elevation head above break location during the draindown event. The

discharge point will depend on the lowest potential drain point for each RPV penetration flow path on a plant-specific basis. This calculation provides a conservative approach to determining the Drain Time of the RPV.

The NRC staff concluded that the licensee will use methods resulting in conservative calculations to determine RPV Drain Time, thereby protecting Safety Limit 2.1.1.3, which meets the requirements of 10 CFR 50.36(c)(3)(1)(i)(A). Based on these considerations, the NRC staff has determined that the licensee's proposed addition of the Drain Time definition to the Browns Ferry TSs to be acceptable.

3.2 Staff Evaluation of Proposed TS 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" The existing TS 3.3.5.2, "Reactor Core Isolation Cooling (RCIC) System Instrumentation," is renumbered as TS 3.3.5.3. This is an editorial change that maintains consistency within the Browns Ferry TSs, and the NRC staff finds this acceptable.

The purpose of the proposed new TS 3.3.5.2 regarding RPV WIC Instrumentation is to support the requirements of revised TS LCO 3.5.2 and the proposed new definition of Drain Time.

There are instrumentation and controls that are required for manual pump starts, as a permissive, or operational controls on the equipment of the systems that provide water injection capability, certain start commands, pump protection, and isolation functions. These instruments are required to be operable if the systems that provide water injection and isolation functions are to be considered operable, as described above in Section 2.2.2.2 of this SE for revised TS 3.5.2.

For Browns Ferry, reactor operators have alternate means, often requiring several more steps to start and inject water than the preferred simple push button start, but these actions can still be accomplished within the timeframes assumed in the development of TSTF-542.

Specifically, the proposed new TS 3.3.5.2 supports operation of the CS and LPCI, including manual starts when needed, as well as the isolation of the shutdown cooling and the RWCU systems. The equipment involved with each of these systems is described in the evaluation of TS 3.5.2. The following sections evaluate the various parts of the new TS 3.3.5.2.

3.2.1 Staff Evaluation of Proposed TS 3.3.5.2 LCO and Applicability In Reference 1, the licensee proposed a new TS 3.3.5.2 to provide alternative instrumentation requirements to support manual initiation of the ECCS injection/spray subsystem and for automatic isolation of penetration flow paths that may be credited in the determination of Drain Time. The current TSs contain instrumentation requirements related to OPDRVs in TS LCOs 3.3.5.1, 3.3.6.1, 3.3.6.2, and 3.3.7.1. The requirements from Tables 3.3.5.1-1 and Table 3.3.6.1-1 would be consolidated into new TS 3.3.5.2. The references to OPDRVs requirements in Tables 3.3.6.1-1, 3.3.6.2-1, and 3.3.7.1-1 would be deleted, as discussed in Section 3.6 of this SE.

The proposed LCO 3.3.5.2 would state:

The RPV Water Inventory Control Instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

The proposed Applicability would state:

According to Table 3.3.5.2-1.

TSTF-542 selected a table to contain those instrumentation functions needed to support manual initiation of the ECCS injection/spray subsystem, as required by LCO 3.5.2, and for automatic isolation of penetration flow paths that may be credited in a calculation of Drain Time. The functions that are required in Mode 4 or 5, or during OPDRVs, are relocated to Table 3.3.5.2-1 from existing TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," and TS 3.3.6.1, "Primary Containment Isolation Instrumentation." Creation of TS 3.3.5.2 places these functions in a single location with requirements appropriate to support the safety function for TS 3.5.2.

The NRC staff concluded that the licensee's proposed alternative is acceptable for Browns Ferry since either the CS or LPCI (or both) subsystems' support instrumentation would be available to perform the intended Function to inject water into the RPV; therefore, this meets the intent of the NRG-approved TSTF-542.

3.2.2 Staff Evaluation of Proposed TS 3.3.5.2 Actions The NRC staff reviewed the licensee's proposed new TS 3.3.5.2 actions to determine whether they provide effective remedial measures when one or more instrument channels are inoperable and cannot complete the required Function in the normal manner. The actions evaluated are as follows:

Action A would be applicable when one or more instrument channels are inoperable from Table 3.3.5.2-1 and directs the licensee to immediately enter the condition referenced in Table 3.3.5.2-1 for that channel.

Action 8 (concerning the shutdown cooling system isolation and RWCU system isolation functions) would be applicable when automatic isolation of the associated penetration flow path is credited as a path for potential drainage in calculating Drain Time. If the instrumentation is inoperable, Required Action 8.1 directs an immediate declaration that the associated penetration flow path(s) are incapable of automatic isolation. Required Action 8.2 requires an immediate recalculation of Drain Time, but automatic isolation of the affected penetration flow paths cannot be credited.

Action C (concerning low reactor steam dome pressure injection permissive function) would address an event in which the permissive is inoperable. The function must be placed in trip condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . With the channel in the trip condition, the manual injection valve opening may be performed using the control board switches. The 1-hour CT is acceptable because, despite the preferred start method being prevented, the reactor operator can take manual control of the pump and the injection valve to inject water into the RPV to achieve the safety function in that time. The time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months also provides reasonable time for the operators to place the channel in trip.

Action D (concerning CS pump discharge flow bypass functions) would address when the bypass is inoperable and there is a possible risk that the associated ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open. In this condition, the operator can take manual control of the pump and the injection valve. Similar to Action C, while this is not the preferred method, the CS subsystem pumps can be started

manually and the valves can be opened manually. The 24-hour CT is acceptable because the functions can be performed manually and it allows time for the operator to evaluate and have necessary repairs completed.

Action E becomes necessary if the required actions and associated CTs of Conditions C or D were not met. If they were not met, then the associated low pressure ECCS injection/spray subsystem might be incapable of performing the intended Function, requiring the CS/LPCI subsystem to be declared inoperable immediately.

These action statements direct the licensee to take appropriate actions and enter into the conditions referenced in Table 3.3.5.2-1. The NRC staff has determined that these actions satisfy the requirements of 10 CFR 50.36(c)(2)(i) by providing remedial actions permitted by the TSs until the LCO can be met. The NRC staff has concluded that there is reasonable assurance that the licensee will take appropriate actions during an unexpected drain event to either prevent or to mitigate the RPV water level being lowered to the TAF; therefore, the proposed actions are acceptable.

3.2.3 Staff Evaluation of Proposed TS 3.3.5.2 SRs The proposed new TS 3.3.5.2 SRs include channel checks and channel functional tests numbered SR 3.3.5.2.1 and SR 3.3.5.2.2, respectively.

SR 3.3.5.2.1 would require a channel check and applies to system isolation functions in TS Table 3.3.5.2-1 for shutdown cooling isolation, RWCU system isolation, and reactor steam dome pressure low for CS and LPCI. Performance of the channel check would ensure that a gross failure of the instrumentation has not occurred. A channel check is normally a comparison of the parameter indicated on one channel to a similar parameter on other related channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. The frequency is once every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , which is consistent with the existing requirements (SR 3.3.5.1.1) and is based on operating experience that demonstrates channel failure is rare.

The SR frequency was previously described in Section 2.2.2.2 of this SE and is further evaluated Section 3.5.1 O of this SE (Variation 10).

SR 3.3.5.2.2 would require a channel functional test and applies to all functions in TS Table 3.3.5.2-1. A channel functional test is performed on each required channel to ensure that the entire channel will perform the intended Function. A channel functional test shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify operability, including required alarm, interlock, display, trip functions, and channel failure trips. The channel functional test may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is tested. The frequency of 92 days is based upon operating experience that demonstrates channel failure is rare.

TSTF-542 did not include SRs to verify or adjust the instrument setpoint derived from the allowable value using a channel calibration or a surveillance to calibrate the trip unit (setpoint).

This is because a draining event in Modes 4 or 5 is not an analyzed accident and, therefore, there is no accident analysis on which to base the calculation of a setpoint. The purpose of the TS 3.3.5.2 functions is to allow ECCS injection/spray manual initiation or to automatically isolate

a penetration flow path, but no specific RPV water level is assumed for those actions.

Therefore, the allowable values for Mode 3 were chosen for use in Modes 4 and 5, as they will perform the desired function. Calibrating the Functions in Modes 4 and 5 is not necessary, as TS 3.3.5.1 and TS 3.3.6.1 continue to require the Functions to be calibrated on an established interval. The NRC staff has determined that the Mode 3 allowable value and established calibration intervals are adequate to ensure the channels will respond with the required accuracy to allow manual initiation of the pumping systems to inject water and automatic isolation of penetration flow paths.

The NRC staff finds that these tests are sufficient and adequate because they will ensure that the Functions of TS 3.3.5.2 are operable (i.e., capable of performing the specified safety function in support of TS 3.5.2, Drain Time, and the protection from a potential drain down of the RPV in Modes 4 and 5). The NRC staff finds that the proposed SRs of LCO 3.3.5.2, are acceptable and concludes that these SRs satisfy 10 CFR 50.36(c)(3) by providing specific SRs relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained.

3.2.4 Staff Evaluation of Proposed Table 3.3.5.2-1, "RPVWater Inventory Control Instrumentation" In order to support the requirements of the proposed TS 3.5.2, the associated instrumentation requirements are designated in Table 3.3.5.2-1. These instruments would be required to be operable if the systems that provide water injection and isolation functions were to be considered operable as described in the NRC staff's evaluation of TS 3.5.2 (Section 3.3 of this SE).

Each of the low pressure ECCS subsystems in Modes 4 and 5 can be started by manual alignment of a small number of components. Automatic initiation of an ECCS injection/spray subsystem may be undesirable because it could lead to overflowing the RPV cavity due to injection rates of thousands of gallons per minute. Thus, manual actuation is preferable and there is adequate time to take manual actions (e.g., hours versus minutes). Considering the action statements as the Drain Time decreases (the proposed TS 3.5.2, Action E, prohibits plant conditions that could result in Drain Times less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ), there is sufficient time for the reactor operators to perform manual action to stop the draining event and to manually start an ECCS injection/spray subsystem or additional method of water injection as needed.

Consequently, there is no need for automatic initiation of the ECCS to respond to an unexpected draining event. The NRC staff finds this acceptable because a draining event is a slow evolution when compared to a design-basis LOCA assumed to occur at a significant power level.

The NRC staff finds this table acceptable because it sufficiently identifies the Functions, the Applicability, the number of required channels, the references to the condition to be entered by letter (e.g., A, B, C) if the Function is inoperable, the applicable SRs, the allowable value for each trip Function, and footnotes concerning items in the table.

The NRC staff finds this RPV WIC instrumentation set is acceptable because it is adequate so that the instrument channels respond with the required accuracy permitting pump systems to inject water when needed and activating isolation equipment when commanded to support prevention or mitigation of a potential RPV draining event.

3.2.4.1 Staff Evaluation of Proposed Table 3.3.5.2-1 Functions Functions 1.a and 2.a in proposed TS Table 3.3.5.2-1 are reactor steam dome pressure - low (injection permissive), for CS and LPCI, respectively. They are used as injection permissives for the low pressure ECCS subsystems. This ensures that prior to opening the injection valves of the low pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems' maximum design pressure. While it is assured during Modes 4 and 5 that the reactor steam dome pressure will be below the ECCS maximum design pressure, the reactor steam dome pressure - low signals are required to be operable and capable of permitting manual operation of the required ECCS subsystem from the control room.

The CS reactor steam dome pressure..: low (permissive) signals are initiated from two pressure transmitters per subsystem that sense reactor steam dome pressure. The transmitters for each subsystem are connected to two trip units. The outputs of the trip units are connected to relays whose contacts are arranged in a one-out-of-two logic. While four channels are available, only two channels per trip system are required to be operable.

The LPCI system reactor steam dome pressure - low signals are initiated from four pressure transmitters (two channels in two trip systems) that sense reactor steam dome pressure. Either trip system can fulfill the Function with a two-out-of-two logic. Therefore, two channels in one trip system are required to be operable.

The reactor steam dome pressure - low signals allowable values for CS and LPCI are low enough to prevent over-pressurizing the equipment in the low pressure ECCS. The proposed allowable value is s 465 pounds per square inch gauge (psig), which is consistent with the existing licensing bases found in Table 3.3.5.1-1.

Variation 4 (see Section 3.5.4 of this SE) further evaluates the required channels per Function for LPCI.

The instruments for Table 3.3.5.2-1 include Function 1.b (CS), pump discharge flow - low (bypass). The minimum flow instruments to protect the CS pump from overheating when the pump is operating and the associated injection valve is not sufficiently open. The minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump.

One flow switch per CS subsystem is used to detect the subsystem flow rate. The logic is arranged such that the flow switch causes the associated subsystem minimum flow valve to open. The logic will close the minimum flow valve once sufficient flow is achieved. The CS spray pump discharge flow - low (bypass) allowable values are high enough to ensure that the pump flow rate is sufficient to protect the pump, yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core. The proposed allowable value is between ~ 1,647 and s 2,91 O gallons per minute (gpm), which is consistent with the existing licensing basis found in Table 3.3.5.1-1.

For Table 3.3.5.2-1, Function 3.a, shutdown cooling system isolation, Reactor Vessel Water Level - Low, Level 3, the Function would only be required to be operable when automatic isolation of the associated penetration flow path is credited in the Drain Time calculation. The proposed number of required instrument channels is one per trip system, which retains the requirement specified in existing TS Table 3.3.6.1-1 Footnote (b ), which states:

Only one channel per trip system required in MODES 4 and 5 when RHR Shutdown Cooling System integrity is maintained.

The condition that the shutdown cooling system integrity be maintained is a concept related to OPDRVs, so it would not be carried over into TS 3.3.5.2 for RPV WIC instrumentation.

The Reactor Vessel Water Level - Low, Level 3 isolation function signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.

While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low, Level 3 Function are available, only two channels (one channel for trip system A and one channel for trip system B) are required to be operable.

The Reactor Vessel Water Level - Low, Level 3 allowable value was chosen to be the same as the primary containment isolation instrumentation Reactor Vessel Water Level - Low, Level 3 allowable value (LCO 3.3.6.1 ), since the capability to cool the fuel may be threatened (~ 528 inches above vessel zero). Variation 6 (see Section 3.5.6 of this SE) further evaluates the required channels per Function for shutdown cooling system.

For Table 3.3.5.2-1, Function 4.a, RWCU system isolation, Reactor Vessel Water Level - Low, Level 3, the Function is only required to be operable when automatic isolation of the associated penetration flow path is credited in the Drain Time calculation. The proposed number of required channels is one per trip system.

The Reactor Vessel Water Level - Low, Level 3 isolation function signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.

While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low, Level 3 Function are available, only two channels (one channel for trip system A and one channel for trip system B) are required to be operable.

The Reactor Vessel Water Level - Low, Level 3 allowable value was chosen to be the same as the RWCU system isolation Reactor Vessel Water Level - Low, Level 3 allowable value (LCO 3.3.6.1 ), since the capability to cool the fuel may be threatened (~ 528 inches above vessel zero). Variation 6 further evaluates the required channels per Function for the RWCU system.

Based on the above considerations, the NRC staff finds that the proposed new LCO 3.3.5.2 correctly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility. There is reasonable assurance that the required actions to be taken when the LCO is not met can be conducted without endangering the health and safety of the public. This meets the requirements of 10 CFR 50.36(c)(2)(i) and, therefore, the staff has determined that the licensee's proposed changes to LCO 3.3.5.2 are acceptable.

3.3 Staff Evaluation of TS 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control" The NRC staff reviewed the water sources that would be applicable to the proposed TS 3.5.2.

The proposed LCO 3.5.2 would state, in part:

One low pressure ECCS injection/spray subsystem shall be OPERABLE.

'One' low pressure ECCS injection/spray subsystem would consist of either one CS subsystem or one LPCI subsystem. A CS subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV. An LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV. Each Browns Ferry unit has a total of four CS pumps and four LPCI pumps, as described in UFSAR Table 6.3-2, "Emergency Core Cooling Systems Equipment Design Data Summary."

The ECCS pumps are high-capacity pumps with flow rates of thousands of gallons per minute (gpm). Most RPV penetration flow paths would have a drain rate on the order of tens or hundreds of gpm. The manual initiation/start of an ECCS pump would provide the necessary water source to counter these expected drain rates. The LPCI subsystem is considered to be operable to perform its safety function, while it is aligned and operating for decay heat removal, if it is capable of being manually realigned. Decay heat removal in Modes 4 and 5 is not affected by the proposed Browns Ferry TS change, as the requirements on the number of shutdown cooling subsystems that must be operable to ensure adequate decay heat removal from the core are unchanged. These requirements can be found in Browns Ferry TS 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown"; TS 3.9.8, "Residual Heat Removal (RHR)- High Water Level"; and TS 3.9.9, "Residual Heat Removal (RHR) - Low Water Level." These Browns Ferry decay heat removal requirements are similar to the STSs and can be found in NUREG-1433: TS 3.4.9, "Residual Heat Removal (RHR)

Shutdown Cooling System - Cold Shutdown"; TS 3.9.8, "Residual Heat Removal (RHR) - High Water Level"; and TS 3.9.10, "Residual Heat Removal (RHR)- Low Water Level." Based on these considerations, the NRC staff finds that the water sources provide reasonable assurance that the lowest functional capability required for safe operation is maintained and the safety limit is protected.

The proposed TS LCO 3.5.2 contains two parts. The first part states that Drain Time of RPV water inventory to the T AF shall be .:: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , and the second part states that one low pressure ECCS injection/spray subsystem shall be operable. The proposed Applicability for TS 3.5.2 is Modes 4 and 5. The proposed LCO 3.5.2 Note states:

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

The NRC staff reviewed the proposed TS 3.5.2, focusing on ensuring that the fuel remains covered with water and on the changes proposed to the current TS. Proposed TS 3.5.2 contains Conditions A through E based on either required ECCS injection/spray subsystem operability or Drain Time.

The current TS LCO states that two low pressure ECCS injection/spray subsystems shall be operable, whereas the proposed LCO 3.5.2 states that one low pressure ECCS injection/spray subsystem shall be operable. This change is reflected in Condition A. The change from two

low pressure ECCS injection/spray subsystems to one low pressure ECCS injection/spray subsystem is acceptable because this redundancy is not required. With one ECCS injection/spray subsystem and non-safety-related injection sources, defense in depth will be maintained. The defense-in-depth measure is consistent with other events considered during shutdown with no additional single failure assumed. The Drain Time controls, in addition to the required ECCS injection/spray subsystem, provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TAF.

The proposed Modes 4 and 5 Applicability of TS 3.5.2 is appropriate, given the TS requirements on ECCS in Modes 1, 2, and 3 will be unaffected. The proposed Condition A states that if the required ECCS injection/spray subsystem is inoperable, it is to be restored to operable status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The proposed Condition B states that if Condition A is not met, a method of water injection capable of operating without offsite electrical power shall be established immediately. The proposed Condition B provides adequate assurance of an available water source should Condition A not be met within the 4-hour CT.

The proposed Condition C states that for a Drain Time < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and .!: 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , to (C.1) verify the secondary containment boundary is capable of being established in less than the Drain Time with a CT of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and (C.2) verify each secondary containment penetration flow path is capable of being isolated less than the Drain Time with a CT of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and (C.3) verify two SGT subsystems are capable of being placed in operation in less than the Drain Time with a CT of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The proposed Condition C provides adequate protection should the Drain Time be < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and .!: 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months because of the ability to establish secondary containment, isolate additional flow paths, and have the SGT subsystems capable of being placed in operations.

The proposed Condition D states that when Drain Time < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to (D.1) immediately initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level> TAF for.!: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , and (D.2) immediately initiate action to establish secondary containment boundary, and (D.3) immediately initiate action to isolate each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room, and (D.4) immediately initiate action to verify two SGT subsystems are capable of being placed in operation. Additionally, there is a Note stating that required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power, which is similar to proposed Condition B.

The current Browns Ferry TSs for Condition D (Required Action C.2 and associated CT not met) are similar to proposed Condition D. The proposed Condition D provides adequate protection should the Drain Time be < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months because of the requirement for the ability to establish an additional method of water injection (without offsite electrical power), establish secondary containment, isolate additional flow paths, and have the SGT subsystems capable of being placed in operation.

Variations 7 and 8 (see Sections 3.5.7 and 3.5.8 of this SE) further describe and evaluate the SGT subsystems. The proposed Condition E states that when the required action and associated CT of Condition C or D is not met, or the Drain Time is < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , then immediately initiate action to restore Drain Time to .!: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The proposed Condition E is new, as it is not present in the current Browns Ferry TSs. The proposed Condition E is acceptable, as it

provides the necessary step to restore the Drain Time to ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months should the other conditions not be met, or if the Drain Time is < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The NRC staff reviewed the proposed changes to TS 3.5.2 and finds them acceptable based on the actions taken to mitigate the water level reaching the T AF with the water sources available and maintaining Drain Time ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The LCO correctly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility. There is reasonable assurance that the required actions to be taken when the LCO is not met can be conducted without endangering the health and safety of the public and, therefore, they are acceptable.

3.3.1 Staff Evaluation of Proposed TS 3.5.2 SRs The proposed TS 3.5.2 SRs include verification of Drain Time, verification of water levels/volumes that support ECCS injection/spray subsystems, verification of water-filled pipes to preclude water hammer events, verification of correct valve positions for the required ECCS injection/spray subsystem, operation of the ECCS injection/spray systems through the test return line, verification of valves credited for automatic isolation actuated to the isolation position, and verification that the required ECCS injection/spray subsystem can be manually operated. Each of the seven SRs is described and evaluated below.

SR 3.5.2.1: The Drain Time would be determined or calculated and required to be verified to be

~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months in accordance with a frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This surveillance would verify that the LCO for Drain Time is met. Numerous indications of changes in RPV level are available to the operator. The period of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate draining of reactor coolant (normally three operator shifts). Changes in RPV level would necessitate recalculation of the Drain Time.

Any changes in plant conditions that would change the Drain Time require that a new Drain Time be determined. The exclusion of penetration flow paths from the determination of Drain Time must consider the potential effects of a single operator error or initiating event on items supporting maintenance and testing (rigging, scaffolding, temporary shielding, piping plugs, snubber removal, freeze seals, etc.).

SR 3.5.2.2 (previously SR 3.5.2.1 ): The suppression pool water level is ~ - 6.5 inches with or

- 7.25 inches without differential pressure control for the required ECCS injection/spray subsystem is required to be verified to ensure pump net positive suction head and vortex prevention. Indications are available either locally or in the control room regarding suppression pool water level. This surveillance would be required to be performed at a frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , which considers operating experience related to suppression pool water level variations and instrument drift. In addition, the 12-hour frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal suppression pool water level condition.

SR 3.5.2.3 (previously SR 3.5.2.2): The SR to verify the ECCS injection/spray subsystem piping is sufficiently filled of water would be retained from the existing TS 3.5.2. The proposed change would update the SR to reflect the change to LCO 3.5.2, which would require, in part, one low pressure ECCS injection/spray subsystem to be operable instead of two. SR 3.5.2.3 wording would change from "Verify, for each required ECCS ... " to "Verify, for the required ECCS ... " This change clarifies the requirement to maintain consistency with the proposed LCO.

Maintaining the pump discharge lines of the required ECCS injection/spray subsystem sufficiently full of water ensures that the ECCS subsystem will perform properly. The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the required ECCS injection/spray subsystems full of water ensures that the ECCS subsystem will perform properly. This may also prevent a water hammer following a manual ECCS initiation. One acceptable method of ensuring that the lines are full is to vent at the high points. The 31-day frequency is based on the gradual nature of void buildup in the ECCS piping, the procedural controls governing system operation, and operating experience .

.SR 3.5.2.4 (previously SR 3.5.2.3): The SR to verify the correct alignment for manual, power-operated, and automatic valves in the required ECCS subsystem flow path would be retained from the existing TS 3.5.2. Similar to the change discussed above for proposed SR 3.5.2.3, changes to SR 3.5.2.4 would clarify a proposed requirement for LCO 3.5.2. The proposed SR wording, "verify, for the required ECCS injection/spray subsystem, each manual. .. " would replace "verify each required ECCS injection/spray subsystem manual. .. "

SR 3.5.2 would provide assurance that the proper flow path will be available for ECCS operation to support TS 3.5.2. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. The 31-day frequency is appropriate because the valves are operated under procedural control, and the probability of their being mispositioned during this time period is low.

The existing Note for SR 3.5.2.3 related to LPCI alignment for decay heat removal has been deleted and a similar Note added to the beginning of proposed LCO 3.5.2.

SR 3.5.2.5: The required ECCS injection/spray subsystem would be required to be operated through its test return line for~ 10 minutes. Testing the ECCS injection/spray subsystem through the test return line is necessary to avoid overfilling the refueling cavity. The minimum operating time of 10 minutes was based on engineering judgment. The performance frequency of 92 days is consistent with similar at-power testing required by SR 3.5.1.6, CS/LPCI pump testing, which includes rated flow and pressures.

The ECCS test return line was previous described in Section 2.2.6.13 of this SE and is further evaluated in Section 3.5.13 (Variation 13 ).

SR 3.5.2.6: Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur. The 24-month frequency is based on the need to perform this surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the surveillance when performed at the 24-month frequency. The frequency was concluded to be acceptable from a reliability standpoint.

The SR frequency was previous described in Section 2.2.3 of this SE and is further evaluated in Section 3.5.10 of this SE (Variation 10).

SR 3.5.2.7 (previously SR 3.5.2.5): The required ECCS subsystem is required to have a manual start capability from a standby configuration. The 24-month frequency is based on the need to perform the surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the surveillance were performed with the reactor at power.

Operating experience has shown that these components usually pass the SR when performed

at the 24-month frequency, which is based on the refueling cycle. Therefore, the frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by a Note that excludes vessel injection/spray during the surveillance.

Since all active components are testable (including the injection valve) and full flow can be demonstrated by recirculation through the test return line, coolant injection into the RPV is not required during the surveillance.

The SR frequency was previously described in Section 2.2.3 of this SE and is further evaluated in Section 3.5.10 (Variation 10). The staff's evaluation of Variation 2 (Section 3.5.2 of this SE) pertains to this SR.

The NRC staff evaluated all of these proposed SRs associated with the new LCO 3.5.2 and concluded they are appropriate for ensuring the operability of the equipment and instrumentation specified in LCO 3.5.2. The NRC staff concluded that all of the proposed SRs are acceptable since they meet the requirements of 10 CFR 50.36(c)(3) for SRs by ensuring that the necessary quality of systems and components is maintained. There is reasonable assurance that the health and safety of the public will not be endangered and, therefore, the SRs are acceptable.

3.4 Staff Evaluation of Proposed TS Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation" LCO 3.3.5.1 currently states:

The ECCS instrumentation for each Function in TS Table 3.3.5.1-1, shall be OPERABLE," with the Applicability as stated in the table. TS Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation," contains requirements for function operability during Modes 4 and 5 when the associated ECCS subsystem(s) are required to be operable.

For the following Functions in TS Table 3.3.5.1-1, the requirements during Modes 4 and 5 would be either deleted or relocated to the proposed TS Table 3.3.5.2-1. Conforming changes were proposed for the actions table of LCO 3.3.5.1 as well.

FUNCTION MODE 4/5 FUNCTION APPLICABILITY RELOCATED TO DELETED TABLE 3.3.5.2-1 1 Core Spray System (a) Reactor Vessel Water Level - Low Low Low, Level 1 Yes (c) Reactor Steam Dome Pressure - Low (Injection No Function 1.a Permissive and ECCS Initiation)

(d) Core Spray Pump Discharge Flow - Low (Bypass) No Function 1.b (e) Core Spray Pump Start- Time Delay Relay Pumps A, B, C, D (with diesel power) Yes Pump A (with normal power) Yes Pump B (with normal power) Yes Pump C (with normal power) Yes Pump D (with normal power) Yes

2 Low Pressure Coolant Injection (LPCI) System (a) Reactor Vessel Water Level - Low Low Low, Level 1 Yes (c) Reactor Steam Dome Pressure - Low (Injection No Function 2.a Permissive and ECCS Initiation)

(f) Low Pressure Coolant Injection Pump Start - Time Delay Relay Yes Pumps A, B, C, D (with diesel power) Yes Pump A (with normal power) Yes Pump B (with normal power) Yes Pump C (with normal power) Yes Pump D (with normal power)

For TS Table 3.3.5.1-1, Functions, 1.a, 1.e, 2.a, and 2.f, the Modes 4 and 5 requirements would not be retained. The Browns Ferry TSs currently require automatic initiation of ECCS pumps on low reactor vessel water level. However, in Modes 4 and 5, automatic initiation of ECCS pumps could result in overfilling the refueling cavity or water flowing into the main steam lines, potentially damaging plant equipment. The NRC staff finds its deletion acceptable because manual ECCS initiation is preferred over automatic initiation during Modes 4 and 5. The deletion of Function 1.e for the CS pump start time delay logic is evaluated in Section 3.5.1 of this SE (Variation 1).

The other three Functions, 1.c, 1.d, and 2.c, would be moved to the proposed TS Table 3.3.5.2-1, as discussed in Section 2.2.6.2 of this SE.

3.5 Staff Evaluation of Proposed Technical Variations The licensee proposed the following technical variations from the TS changes described in TSTF-542 or the applicable parts of the NRC staff's SE. The licensee stated in the LAR (Reference 1) that these variations do not affect the Applicability of TSTF-542 or the NRC staff's SE to the proposed license amendments. The NRC staff evaluated each variation as described below.

3.5.1 Variation 1, Table 3.3.5.1-1, Function 1.e, Core Spray Pump Start - Time Delay Relay (The licensee's proposed variation is described in Section 2.2.6.1 of this SE.)

The NRC staff has evaluated the licensee's stated purpose of the time delay relays is to stagger the automatic start of the four CS pumps, thus limiting the starting transients on the 4 kV essential buses. The NRC staff has determined that a time delay is unnecessary for manual operation; therefore, the NRC staff concludes that Variation 1, as proposed, is acceptable to be removed from the TSs.

3.5.2 Variation 2, Manual Initiation of ECCS Injection/Spray (The licensee's proposed variation is described in Section 2.2.6.2 of this SE.)

The NRC staff reviewed the licensee's proposed alternative and determined that although Browns Ferry does not have the capability to start an ECCS subsystem with a single push button, the components that provide ECCS injection/spray into the RPV can be started from the

main control room (MCR), as required, to support Modes 4 and 5 operations. The manipulation of low pressure ECCS subsystem components from the MCR would be verified in accordance with new SR 3.5.2.7. This SR verifies that the required CS or LPCI subsystem (including associated pump switches and valves) can be manually operated to provide additional RPV water inventory, if needed. Therefore, the NRC staff concludes that Variation 2, as proposed, is acceptable.

3.5.3 Variation 3, Table 3.3.5.2-1, Function 1.d, Core Spray Pump Discharge Flow - Low (Bypass)

(The licensee's proposed variation is described above in SE Section 2.2.6.3.)

The NRC staff has determined that since channel check for this Function has no impact on manual CS injection capability, the licensee will retain its current licensing basis for these instruments. Therefore, the NRC staff concludes that Variation 3, as proposed, is acceptable.

3.5.4 Variation 4, Table 3.3.5.1-1, Function 2.c, LPCI System Reactor Steam Dome Pressure

- Low (Injection Permissive and ECCS Initiation)

(The licensee's proposed variation is described in Section 2.2.6.4 of this SE.)

The NRC staff evaluated this variation and Section 3.3 of the TSTF-542 SE, which states that only one ECCS injection/spray subsystem is required to be operable in Modes 4 and 5, as no additional single failure is assumed. The NRC staff determined that the licensee's variation to have "2 channels in 1 trip system" for LPCI low reactor steam dome pressure is equivalent to the TSTF-542 requirement that states all four channels must be operable. They are equivalent because TS Table 3.3.5.2-1 Footnote (a) specifies that only those channels associated with the required ECCS subsystem per LCO 3.5.2 must be operable. The licensee's proposed variation maintains the instrumentation requirement for LPCI injection permissive; therefore, the NRC staff concludes that Variation 4, as proposed, is acceptable.

3.5.5 Variation 5, Table 3.3.5.1-1, Function 2.g, LPCI Pump Discharge Flow - Low (Bypass)

(The licensee's proposed variation is described in Section 2.2.6.5 of this SE.)

The NRC staff has determined that the Browns Ferry RHR minimum flow design is different from the NUREG-1433 reference plant (STS). The STS and the present Browns Ferry TSs do not have these pump discharge low flow TS instruments. The STS design is a minimum flow line with a valve that opens/closes on sensed flow from a flow transmitter. At Browns Ferry, RHR/LPCI pump protection for overheating is designed with an open flow path with a valve that does not automatically open/close on transmitter sensed flow. Therefore, the NRC staff concludes that Variation 5, as proposed, is acceptable.

3.5.6 Variation 6 1 Table 3.3.5.2-1, Function 3.a, Shutdown Cooling System Isolation -

Reactor Vessel Water Level - Low, Level 3, and Function 4.a, RWCU System Isolation

- Reactor Vessel Water Level - Low, Level 3

{The licensee's proposed variation is described in Section 2.2.6.6 of this SE.)

The NRC staff has determined that the logic design for Browns Ferry is different from the NUREG-1433 reference plant (STS). The Browns Ferry logic is four channels arranged with

two channels in Trip System A and two channels in Trip System B. They are arranged in a one-out-of-two-taken twice logic, which isolates both the inboard and outboard isolation valves.

Thus, for new Table 3.3.5.2-1, Function 3.a, one required channel per trip system is specified.

This is consistent with the existing requirements in Table 3.3.6.1-1 Footnote {b). The closure logic is the same for the RWCU isolation valves. Therefore, new Table 3.3.5.2-1, Function 4.a, similarly specifies one required channel per trip system.

The NRC staff has determined that the differences between the Browns Ferry and the STS requirements for RWCU and RHR/SDC system trip systems do not negatively affect the ability of Browns Ferry to initiate system isolation when needed to support Drain Time. The NRC staff concludes that any single channel will trip its associated trip string and trip system; therefore, Variation 6, as proposed, is acceptable.

3.5.7 Variation 7, Secondary Containment Design and TS 3.5.2 Required Actions C.3 and D.4, Standby Gas Treatment Subsystems (The licensee's proposed variation is described in Section 2.2.6. 7 of this SE.)

The NRC staff has determined that the Browns Ferry SGT subsystems are different from the STS such that this three-unit facility has shared SGT subsystems with a total of three trains being shared for three units. STS 3.6.4.3 states, "Two trains of SGTS shall be Operable," for a single unit. TS 3.6.4.3 presently requires three SGT subsystems be operable in Modes 1, 2, and 3, and during OPDRVs. For Browns Ferry, two trains of SGT subsystem versus one train of SGT subsystem will be needed in order to satisfy the Drain Time required actions set forth in TSTF-542; therefore, the NRC staff concludes that Variation 7, as proposed, is acceptable.

3.5.8. Variation 8 1 Shared Common Refueling Floor and Shared SGT Subsystems, TS 3.5.2, Required Action D.3 (The licensee's proposed variation is described in Section 2.2.6.8 of this SE.)

In accordance with TSTF-542, TS 3.5.2 Required Action D.3 states:

Initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room.

Proposed TS 3.5.2 Required Action D.3 states:

Initiate action to isolate each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

The NRC staff has determined that the Browns Ferry SGT subsystems with a common refueling floor are different from the STS such that this three-unit facility has shared SGT systems, with a total of three trains being shared for three units, with a common refueling floor shared. With three units, the secondary containment, SCIVs, and the SGT system are maintained operable per an online unit. In accordance with the existing Browns Ferry TSs, for TS 3.6.4.1, "Secondary Containment," the secondary containment shall be operable in Modes 1, 2, and 3, and during OPDRV; for TS 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)," each SCIV shall be operable in Modes 1, 2, and 3, and during OPDRV; and for TS 3.6.4.3, "Standby Gas Treatment (SGT) System," three SGT subsystems shall be operable in Modes 1, 2, and 3, and during OPDRV. The NRC staff finds the addition of

'automatic or' isolation of secondary containment penetrations to the proposed TS 3.5.2, Required Action D.3, acceptable since these systems, as noted above, are shared between units, and the other units may be in different modes. Therefore, the NRC staff concludes that Variation 8, as proposed, is acceptable.

3.5.9 Variation 9, TS 3.8.2, AC Sources - Shutdown, SR 3.8.2.1 Note and SR Exceptions (The licensee's proposed variation is described above in Section 2.2.6.9 of this SE.)

Browns Ferry SR 3.8.2.1, Units 1 and 2, presently states:

NC>TE------------------------------------------------ ,__ _

The following SRs are not required to be performed: SR 3.8.1.2, SR 3.8.1.5, SR 3.8.1.7, SR 3.8.1.8, and SR 3.8.1.9.

For Unit 1 and 2 AC sources required to be OPERABLE, the SRs of Specification 3.8.1 are applicable.

Browns Ferry SR 3.8.2.1, Unit 3, presently states:

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

The following SRs are not required to be performed: SR 3.8.1.2, SR 3.8.1.5, SR 3.8.1.7, SR 3.8.1.8, and SR 3.8.1.9.

For Unit 3 AC sources required to be C>PERABLE, the SRs of Specification 3.8.1 are applicable.

(Emphasis is added to show the difference between BFN units.)

However, with the adoption of TSTF-542, there is no longer a need for an emergency diesel generator (EDG) auto-start on an accident signal in Modes 4 and 5. Accordingly, SR 3.8.1.9, "Verify, on an actual or simulated LOOP signal in conjunction with an actual or simulated ECCS initiation signal ... ," may be removed from the SR 3.8.2.1 Note and listed as an exception to this SR. Similarly, SR 3.8.1.6, "Verify on an actual or simulated accident signal each DG auto-starts from standby condition," is no longer necessary and may be included as an exception to SR 3.8.2.1. Changes are also made to the Browns Ferry, Unit 3, SR 3.8.2.1 related to the Unit 3 AC sources required to be operable.

The NRC staff has determined that the SR 3.8.2.1 Note (TS 3.8.2, AC Sources- Shutdown) can be modified to delete the reference to SR 3.8.1.9 since SR 3.8.1.9 is added as a proposed SR 3.8.2.1 exception. Also, SR 3.8.1.6 is added as a proposed SR 3.8.2.1 exception.

Following the adoption of TSTF-542, as proposed, no ECCS initiation signal will be provided in Modes 4 and 5. This revision will continue to ensure that the required AC sources are adequately tested without unnecessarily rendering them inoperable during shutdown periods when the available AC sources are limited, since these two SR exceptions are tested in accordance with TS 3.8.1, AC Sources - C>perating. The identified difference noted above between the units is not part of the considered changes and is simply added here for completeness. Therefore, the NRC staff concludes that Variation 9, as proposed, is acceptable.

3.5.10 Variation 10, Surveillance Frequencies (The licensee's proposed variation is described in Section 2.2.6.10 of this SE.)

The NRC staff determined that for SR 3.3.5.2.1, this proposed channel check frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is consistent with the current licensing basis for these Functions formerly performed as part of TSs 3.3.5.1 and 3.3.6.1 (perform channel check) versus 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , which is in accordance with the STS and TSTF-542. For SRs 3.5.2.6 and 3.5.2.7, TSTF-542 has this frequency defined as [18] months. The Browns Ferry proposed change to a SR frequency of 24 months correlates to performance once every refueling cycle. Browns Ferry has a 24-month refueling cycle; therefore, the NRC staff concludes that Variation 10, as proposed, is acceptable.

3.5.11 Variation 11, Table 3.3.7.1-1, Control Room Emergency Ventilation System Instrumentation, Footnote (a)

(The licensee's proposed variation is described in Section 2.2.6.11 of this SE.)

The NRC staff has determined that the STS and Browns Ferry licensing bases are slightly different in TS Functions and noun name terminology as they relate to the ventilation systems that isolate the control rooms (CREV) from outside air. These automatic actions are required to mitigate the consequences of the LOCA or fuel handling accident involving recently irradiated fuel by limiting the control room doses to less than the limits calculated in the safety analysis. In accordance with TSTF-542, the OPDRV footnote is removed from all Functions in Browns Ferry TS Table 3.3.7.1-1 and, thus, carried out for Browns Ferry Table 3.3.7.1-1, Function 3, "Reactor Zone Exhaust Radiation - High"; Function 4, "Refueling Floor Exhaust Radiation - High"; and Function 5, "Control Room Air Supply Duct Radiation - High." Therefore, the NRC staff concludes that Variation 11, as proposed, is acceptable.

3.5.12 Variation 12, LCO 3.5.2 Note, Alignment, and Operation for Decay Heat Removal (The licensee's proposed variation is described in Section 2.2.6.12 of this SE.)

The NRC staff has determined that the added footnote to LCO 3.5.2 associated with the LPCI subsystem is appropriate and is consistent with TSTF-542, which places this Note within the LCO. Without the Note, the associated RHR pump would be declared inoperable, which would be contrary to the intent of the existing Note for SR 3.5.2.4, which allows the LPCI subsystem to be operable when aligned for decay heat removal; therefore, the NRC staff concludes that Variation 12, as proposed, is acceptable.

3.5.13 Variation 13, Proposed New SR 3.5.2.5, ECCS Injection/Spray Subsystem Testing (The licensee's proposed variation is described in Section 2.2.6.13 of this SE.)

The NRC staff has determined that the replacement of the phrase through the "recirculation line" with "test return line" is acceptable since the intent of this SR was to test and verify pump ECCS injection/spray flow is available to mitigate a draindown event. Therefore, the NRC staff concludes that Variation 13, as proposed, is acceptable.

3.5.14 Variation 14. TS 3.6.1.3, Primary Containment Isolation Valves (PCIVs), Applicability, Note 4, Condition E (The licensee's proposed variation is described in Section 2.2.6.14 of this SE.)

The NRC staff has determined that for TS 3.6.1.3, Condition E, and Note 4, the reference to "Mode 1, 2, and 3" can be deleted since these are unnecessary, given the new requirements set forth in TSTF-542, Drain Time, and WIC for Modes 4 and 5. This variation is consistent with the treatment of other primary containment isolation instruments as discussed in Section 3.4.1.2, "TS 3.3.6.1A and 3.3.6.1b, Primary Containment Isolation Instrumentation" (Reference 3), and in Section 3.4.2, "Other Proposed Changes - Containment, Containment Isolation Valves, and Standby Gas Treatment Requirements," of the justification for TSTF-542, Revision 2 (Reference 4). The Applicability for TS 3.6.1.3 is revised with the deletion of "When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation"; therefore, the NRC staff concludes that Variation 14, as proposed, is acceptable.

3.5.15 Variation 15, TS 3.6.1.3, Primary Containment Isolation Valves (PCIVs), Condition F (The licensee's proposed variation is described in Section 2.2.6.15 of this SE.)

The NRC staff has determined that for Browns Ferry TS 3.6.1.3, Condition F would no longer be applicable since the RPV WIC requirements would be consolidated into TSs 3.3.5.2 and 3.5.2, the Modes 4 and 5 requirements in TS 3.6.1.3. Therefore, the NRC staff concludes that Variation 15, as proposed, is acceptable.

3.5.16 Variation 16, Removal of 'Mode 1, 2 and 3' from Secondary Containment, SCIVs, SGT, and CREVTSs (The licensee's proposed variation is described in Section 2.2.6.16 of this SE.)

The NRC staff determined that for TSs 3.6.4.1, 3.6.4.2, 3.6.4.3, and 3. 7.3, conditions that are referenced to "MODE 1, 2, and 3," can be deleted since these conditions are unnecessary, given the new requirements set forth in TSTF-542, Drain Time, and WIC for Modes 4 and 5. This variation is consistent with the treatment of containment as discussed in Section 3.4.2, "Other Proposed Changes - Containment, Containment Isolation Valves, and Standby Gas Treatment Requirements," and Section 3.4.3, "Other Proposed Changes - Control Room Habitability and Temperature Control Requirements," of the justification for TSTF-542, Revision 2 (Reference 3).

The Applicability for these four TSs is revised with the deletion of "during operations with a potential for draining the reactor vessel (OPDRVs)"; therefore, the NRC staff concludes that Variation 16, as proposed, is acceptable.

3.5.17 Variation 17, Preferred Pump Logic (Browns Ferry, Units 1 and 2, Only)

(The licensee's proposed variation is described in Section 2.2.6.17 of this SE.)

This variation was provided by the licensee (Reference 2) in response to staff questions regarding the unique design of various instrumentation and control relays integrated into the Browns Ferry, Units 1 and 2, electrical system. (Variation 17 is not applicable to Unit 3.)

The Browns Ferry, Units 1 and 2, 4 kV electrical buses are designed to use a Preferred Pump Logic (PPL). During a Unit 1 design-basis accident LOCA, the PPL will trip the Unit 2 operating low pressure ECCS pumps. This tripping logic is similarly true for the reversed condition of Unit 2 having the design-basis accident LOCA. This design preserves 4 kV electrical bus loading requirements to start safety-related loads on the accident unit. Additionally, the manual start of the required low pressure ECCS pump (per TS LCO 3.5.2) on the non-accident unit is inhibited (locked out) for a period of 60 seconds. Once the time delay or lockout clears, MCR operators on the non-accident unit will have the capability to manually start the required low pressure ECCS pump for RPV water injection, if needed. This is subject to the electrical loading status on the Units 1 and 2 4 kV shutdown boards that may have been impacted by the accident unit. The operation of PPL is identical, whether there is a LOCA coincident with a LOOP or a LOCA with offsite power remaining available.

Proposed TS LCO 3.5.2 requires one low pressure ECCS injection/spray subsystem to be Operable in Modes 4 and 5. Also, Drain Time of RPV water inventory to the TAF shall be

.?: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . If the required ECCS injection/spray subsystem is inoperable, the Completion Time is 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for restoration of an ECCS injection/spray subsystem (Required Action A.1 ). If this Required Action is not met, immediately initiate action to establish a method of water injection capable of operating without offsite electrical power. The 4-hour Completion Time for restoring the required ECCS injection/spray subsystem is based on engineering judgment that considers the LCO controls on Drain Time and the low probability of an unexpected RPV drain event that would result in the loss of RPV water inventory.

For the event described above, with the calculated Drain Time (non-accident unit) to be

.?: 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , the NRC staff determined that the required low pressure ECCS subsystem pump would be locked out for 60 seconds, TS 3.5.2 Condition A would be entered until the time delay cleared and the MCR operators verified that sufficient electrical margin existed on the Units 1 and 2 4 kV shutdown boards to start the required low pressure ECCS pump, if needed.

Electrical bus restoration will be accomplished within the 4-hour CT of LCO 3.5.2, Condition A, since electrical power to the required ECCS pump would be supplied by one of the available eight EDGs between the three Browns Ferry units with breaker ties to the shutdown buses. Specifically, in the event of a LOOP and a design-basis accident on any one unit, the NRC staff determined that for the long-term operations (greater than 10 minutes), three of the Units 1 and 2 EDGs, coupled with three respective EDGs from Unit 3, would be adequate to supply required loads for the safe shutdown and cooldown of all three units. This is considered to be an effective defense-in-depth measure since the electrical paralleling of an EDG is not required to safely shutdown and cool all three units following an accident in one unit and LOOP.

The above analysis is similarly true when the calculated Drain Time (non-accident unit) is

.?: 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (proposed TS LCO 3.5.2, Condition D). However, there are added conservatisms or mitigating TS required actions that should be implemented for an unexpected RPV drain event. For example, (1) Required Action D. 1 requires additional water injection methods without offsite electrical power to be initiated. (Note: Since Browns Ferry has the capability to cross-connect eight EDGs to supply 4 kV bus loads, electrical power for the alternate RPV water injection methods is expected to be functional without offsite electrical power); (2) Required Action D.2 requires secondary containment boundary actions to be initiated; (3) Required Action D.3 requires secondary containment penetration flow path isolation actions to be initiated; and (4) Required Action D.4 requires verification that an SGT subsystem is capable of being placed into operation.

The NRC staff determined that in the event of a LOOP and a design-basis accident on any one unit for the long-term operations (greater than 1O minutes), three of the Units 1 and 2 EDGs, coupled with three respective EDGs from Unit 3, would be adequate to supply required loads for the safe shutdown and cooldown of all three units. The NRC staff considers that there is a very low probability that a Browns Ferry non-accident unit (Units 1 or 2) would experience a loss of RPV inventory due to an unexpected drain event during a concurrent design-basis LOOP/LOCA (accident unit) at the other unit. In the event of a LOOP at the three units and a concurrent loss of RPV inventory at one unit, the three EDGs on Units 1 and 2, coupled with the capability to manually align at least three EDGs from Unit 3, provides reasonable assurance that all three Browns Ferry units can be maintained in safe shutdown conditions for an extended duration.

The NRC staff, therefore, concludes that Variation 17, as proposed, is acceptable.

3.5.18 Variation 18, Common Accident Signal (Units 1, 2, and 3)

(The licensee's proposed variation is described in Section 2.2.6.18 of this SE.)

The NRC staff evaluated the licensee's furnished information and determined that the CAS logic design does not adversely impact the TS operability of a low pressure ECCS subsystem credited per the proposed TS 3.5.2 in Modes 4 and 5 if a LOCA occurs in another Browns Ferry unit operating in Modes 1, 2, or 3, either with or without a coincident LOOP to that unit.

Specifically, the stripping of electrical bus is quickly recoverable with the bus restoration when the associated DGs reenergize the Unit 4 kV shutdown board. Once the electrical bus is recovered, plant operator actions are necessary to start required ECCS pumps that support the low probability of an unexpected draindown event. CAS has no effects on the ability to automatically restore power to the low pressure ECCS subsystem credited per TS 3.5.2.

Therefore, the NRC staff concludes that Variation 18, as proposed, is acceptable.

3.5.19 Variation 19, Unit Priority Re-Trip Logic (Units 1, 2, and 3)

(The licensee's proposed variation is described in Section 2.2.6.19 of this SE.)

The NRC staff evaluated the licensee's furnished information and determined that the Unit Priority Re-trip Logic design does not adversely impact the TS operability of a low pressure ECCS subsystem credited per the proposed TS 3.5.2 in Modes 4 and 5 if a LOCA occurs in another Browns Ferry unit operating in Modes 1, 2, or 3, either with or without a coincident LOOP to that unit. Specifically, the (electrical) stripping of the bus is quickly recoverable when the associated DGs reenergize the Unit 4 kV shutdown board. Once the electrical bus is recovered, plant operator actions are necessary to start necessary ECCS pumps that support the low probability of an unexpected draindown event. Unit priority re-trip logic has no effects on the ability to automatically restore power to the low pressure ECCS subsystem credited per TS 3.5.2 since the non-accident units' diesels will be unaffected by this second breaker trip.

Thus, each unit is given priority over the block of subsequent CAS diesel breaker trips for its diesels. Therefore, the NRC staff concludes that Variation 19, as proposed, is acceptable.

3.6 Staff Evaluation of Proposed Deletion of Reference to OPDRVs Term Section 2.2.4.1 of this SE lists the numerous OPDRV references proposed for deletion. The changes would replace the existing specifications related to OPDRVs with revised specifications for RPV WIC. For example, the proposed changes would remove:

Only one channel per trip system required in Modes 4 and 5 when RHR shutdown cooling system integrity is maintained

During operations with a potential for draining the reactor vessel

During operations with a potential for draining the reactor vessel (OPDRVs)

Initiate action to suspend OPDRV

Initiate action to suspend operations with a potential for draining the reactor vessel ( OPDRV)

The term OPDRVs is not specifically defined in the TSs and historically has been subject to inconsistent application by licensees. The changes discussed in this SE are intended to resolve any ambiguity by creating a new RPV WIC TS with attendant equipment operability requirements, required actions, and SRs, and deleting references to OPDRVs throughout the TSs.

The current Browns Ferry TSs contain instrumentation requirements related to OPDRVs in four TSs; three sections currently have the OPDRV phrases described above. The proposed TS 3.3.5.2 consolidates the instrumentation requirements into a single location to simplify the presentation and provide requirements consistent with TS 3.5.2. The remaining TSs with OPDRVs requirements are for secondary containment, primary and secondary containment isolation valves, SGT system, control room emergency ventilation system (CREV), control room air conditioning system, and electrical sources. Each of these system's requirements during OPDRVs was proposed for consolidation into revised TS 3.5.2 for RPV WIC based on the appropriate plant conditions and calculated Drain Time.

The NRC staff determined that the deletion of OPDRV references, along with the corresponding editorial changes are appropriate, because the proposed TSs governing RPV WIC and the associated instrumentation, TSs 3.5.2 and 3.3.5.2, respectively, are clarified and simplified as an alternative set of controls for ensuring water level is maintained above Safety Limit 2.1.1.3; therefore, the NRC staff concludes the changes, as proposed, are acceptable.

3.7 TS 3.10, Special Operations and TSTF-484, Revision 0 The current Browns Ferry TSs describe TS LCO 3.10.1, "lnservice Leak and Hydrostatic Testing Operations," allowing performance of an inservice leak or hydrostatic test with the average reactor coolant temperature greater than 212 degrees Fahrenheit (°F), while considering operational conditions to still be in Mode 4, provided certain secondary containment LCOs were met.

TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities," revised LCO 3.10.1 to expand its scope to include operations where temperature exceeds 200 °F: (1) as a consequence of maintaining adequate reactor pressure for an inservice leak or hydrostatic test, or (2) as a consequence of maintaining adequate reactor pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test.

By Amendment Nos. 270, 299, and 258 (Browns Ferry, Units 1, 2, and 3, respectively), dated April 16, 2007, the NRC approved changes to Browns Ferry TS LCO 3.10.1 in accordance with TSTF-484 (Reference 8). The NRC staff's SE for these amendments stated, in part:

... two low-pressure emergency core cooling systems (ECCSs) injection/spray subsystems are required to be operable in Mode 4 by TS 3.5.2, ECCS-Shutdown.

However, per the proposed new LCO 3.5.2, only one low pressure ECCS subsystem would be required to be operable in Mode 4.

The NRC staff determined that changing from two ECCS injection/spray subsystems to one ECCS injection/spray subsystem is acceptable because, as stated previously in Section 3.3 of this SE, this level of redundancy is not required, even during application of LCO 3.10.1. When the licensee applies LCO 3.10.1 at the end of a refueling outage, an exceptionally large volume of water is present in the reactor vessel since the vessel is nearly water solid. There is much more water in the reactor vessel than is present during power operation and more than is present during most of an outage. Small leaks from the reactor coolant system would be detected by inspections before a significant loss of inventory occurred. In the event of a large reactor coolant system leak, the RPV would rapidly depressurize and allow operation of the low pressure ECCS. At low decay heat values and near Mode 4 conditions, the stored energy in the reactor core will be very low. Therefore, the reasoning that operators would have time to respond with manual actions to start any ECCS pumps and properly align valves for injection from the control room remains valid.

As stated previously in Section 3.3 of this SE, with one ECCS injection/spray subsystem and non-safety-related injection sources, defense in depth will be maintained. The defense-in-depth measure is consistent with other events considered during shutdown with no additional single failure assumed. The Drain Time controls, in addition to the required ECCS injection/spray subsystem, provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the Safety Limit of TS 2.1.1.3.

On the bases of the NRC staff's evaluation, using the reasoning presented elsewhere in this SE, the SE for TSTF-542 (Reference 4), including an additional review of the SE for Browns Ferry TS 3.10.1 (Reference 8), and the model SE for TSTF-484 (71 FR 63050, dated October 27, 2006), the staff has determined that proposed LCOs 3.3.5.2 and 3.5.2 continue to represent either the lowest functional capability or performance level of equipment required for safe operation of the facility and, therefore, the NRC staff concludes that the changes, as proposed, are acceptable.

3.8 Technical Conclusion Browns Ferry Safety Limit 2.1.1.3 requires that "Reactor vessel water level shall be greater than the top of active irradiated fuel." Maintaining water level above the TAF ensures that the fuel cladding fission product barrier is protected during shutdown conditions. The proposed TS changes evaluated within this SE establish new LCO requirements that address the preventive and mitigative equipment and associated instrumentation that provide an alternative means to support Safety Limit 2.1.1.3 during Modes 4 and 5 operations.

The reactor coolant system is at a low operating temperature(< 212 °F) and is depressurized during Modes 4 and 5 conditions. An event involving a loss of inventory while in the shutdown condition does not exceed the capacity of one ECCS subsystem. The accident that is postulated to occur during shutdown conditions, the design-basis refueling accident (UFSAR Section 14.11.4) does not involve a loss of inventory. Therefore, the equipment and instrumentation associated with the reactor vessel WIC TSs do not provide detection or mitigation related to these DBAs.

The proposed TS LCO 3.5.2 contains requirements for operability of one ECCS subsystem along with requirements to maintain a sufficiently long Drain Time so that plant operators would

have time to diagnose and mitigate an unplanned draining event. The NRC staff has determined that LCOs 3.5.2 and 3.3.5.2 provide for the lowest functional capability or performance levels of equipment required for safe operation of the facility and, therefore, meet the LCO requirements of 10 CFR 50.36(c)(2)(i).

Additionally, the revised TS LCOs 3.5.2 and 3.3.5.2 provide remedial actions to be taken in the event the LCO is not satisfied and, therefore, meet the requirements of 10 CFR 50.36(c)(2)(i).

The NRC staff finds that the proposed TS action statements provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TAF.

The NRC staff evaluated the proposed Drain Time definition, TS 3.5.2, which contains the requirements for RPV WIC and TS 3.3.5.2, which contains the requirements for instrumentation necessary to support TS 3.5.2. Based on the considerations discussed above, the NRC staff concludes that the proposed revisions are acceptable because they consolidate and clarify the RPV WIC requirements.

The licensee proposed to delete OPDRV references from the TS Applicability descriptions, conditions, required actions, and footnotes. The NRC staff reviewed the proposed changes and determined that the deletion of OPDRV references, along with the corresponding editorial changes, are appropriate because the proposed TSs governing RPV WIC and the associated instrumentation, TSs 3.5.2 and 3.3.5.2, respectively, are a clarified and simplified alternative set of controls for ensuring that water level is maintained above the TAF.

The NRC staff reviewed the SRs associated with the new LCOs 3.5.2 and 3.3.5.2. The NRC staff finds that the proposed TS SRs in TS 3.5.2 are acceptable since they support TS 3.5.2 Drain Time requirements; assure that water inventory is available for ECCS injection/spray subsystem RPV injection and pump performance; ECCS injection/spray subsystems are adequately filled with water (mitigates effects of gas accumulation or voiding); the subsystems have verified valve positions to support RPV injection, verified pumps provide adequate flow to support Drain Time and RPV injection and verification of automatic isolation; and ECCS injection/spray subsystems can be manually operated. The NRC staff finds that the two SRs proposed for TS 3.3.5.2 are sufficient and adequate because they ensure that the Functions are capable of performing their specified safety functions in support of TS 3.5.2, Drain Time, and the protection from a potential drain down of the RPV in Modes 4 and 5. Therefore, the NRC staff concludes that the proposed SRs satisfy 10 CFR 50.36(c)(3).

The NRC staff evaluated the proposed Browns Ferry changes against each of the unit's applicable design requirements listed in Section 2.3.1 of this SE. The NRC staff finds that the proposed changes for Modes 4 and 5 operations, as they relate td the proposed TS changes for the new Drain Time definition and the removal of OPDRV references, remain consistent with the proposed GDC that were used to evaluate the original design of Browns Ferry in that the Browns Ferry design requirements for instrumentation, reactor coolant leakage detection, the reactor coolant pressure boundary, and reactor coolant makeup are unaffected. The NRC staff evaluated 19 variations and found these acceptable.

The regulation in 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application but shall not become part of the TSs. In accordance with this requirement, the licensee provided TS Bases changes in the proposed LAR. The NRC staff notes that the TS

Bases changes provided describe the basis for the affected TSs and follow the Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors (58 Federal Register 39132).

Additionally, the proposed TS changes were reviewed for technical clarity and consistency with the existing Browns Ferry requirements for customary terminology and formatting. The NRC staff found that the proposed changes were consistent with TSTF-542, Revision 2 (Reference 3), and Chapter 16 of the SRP (Reference 5).

In summary, the NRC staff finds that the revised TSs to adopt TSTF-542 will provide reasonable assurance the health and safety of the public will not be endangered.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Alabama State official was notified of the proposed issuance of the amendments on November 22, 2019. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change the requirements with respect to installation or use of a facility's components located within the restricted area as defined in 10 CFR Part 20 and change SRs.

The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration (84 FR 19974), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1 Letter from Tennessee Valley Authority to U.S. NRC, "Browns Ferry Nuclear Plant, Units 1, 2, and 3, Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF)-542, 'Reactor Pressure Vessel Water Inventory Control,' Revision 2," dated January 25, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19031C826).

2 Letter from Tennessee Valley Authority to U.S. NRC, "Browns Ferry Nuclear Plant, Units 1, 2, and 3, Response to NRC Request for Additional Information Regarding

Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF)-542, "'Reactor Pressure Vessel Water Inventory Control,' Revision 2,"

dated August 8, 2019 (ADAMS Accession No. ML19220C034).

3 Enclosure to TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control,"

dated March 14, 2016 (ADAMS Accession No. ML16074A448).

4 Letter from U.S. NRC to Technical Specifications Task Force, "Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-542, Revision 2, 'Reactor Pressure Vessel Water Inventory Control,"' dated December 20, 2016 (ADAMS Accession No. ML16343B008).

5 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, "Technical Specifications," Revision 3 (NUREG-0800, Chapter 16), dated March 2010 (ADAMS Accession No. ML100351425).

6 U.S. NRC, "Standard Technical Specifications, General Electric BWR/4 Plants,"

NUREG-1433, Volume 1, "Specifications," Rev. 4.0, dated April 2012 (ADAMS Accession No. ML12104A192).

7 U.S. NRC, "Standard Technical Specifications, General Electric BWR/4 Plants,"

NUREG-1433, Volume 2, "Bases," Rev. 4.0, dated April 2012 (ADAMS Accession No. ML12104A193).

8 U.S. NRC letter to Tennessee Valley Authority, Browns Ferry Nuclear Plant, Units 1, 2, and 3; Issuance of Amendments Regarding Scram Time Testing Activities, dated April 16, 2007 (ADAMS Package Accession No. ML070650326).

Principal Contributors: L. Wheeler J. Wilson K. West G. Matharu Date: December 26, 2019

J. Barstow

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 - ISSUANCE OF AMENDMENT NOS. 311, 334, AND 294 TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER, TSTF-542, REVISION 2, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" (EPID L-2019-LLA-0010) DATED DECEMBER 26, 2019 DISTRIBUTION:

PUBLIC RidsNrrDexEeob Resource PM File Copy LWheeler, NRR RidsNrrDorlLpl2-2 Resource JWilson, NRR RidsNrrPMBrownsFerry Resource KWest, NRR RidsNrrLALRonewicz Resource MGurcharan, NRR RidsACRS_MailCTR Resource RidsNrrLABAbeywickrama Resource RidsRgn2Mai1Center Resource RidsNrrDssSnsb Resource RidsNrrDssStsb Resource GMatharu, NRR RidsNrrDexEicb Resource ADAMS A ccess1on No.: ML19294A011 *b,v memoran d um or e-ma,*1 OFFICE DORL/LPL2-2/PM DORL/LPL2-2/LA DEX/EICB/BC(A)* DSS/SNSB/BC(A)* DEX/EEOB/BC(A)*

NAME MWentzel LRonewicz WMorton JBorromeo DWilliams (RHaskell for)

DATE 11/1/2019 10/31/2019 09/27/2019 10/09/2019 10/09/2019 OFFICE DSS/STSB/BC* OGC-NLO DORL/LPL2-2/BC DORL/LPL2-2/PM (as revised)

NAME VCusumano STurk UShoop MWentzel (THood for) (FSaba for)

DATE 10/09/2019 11/22/2019 12/26/2019 12/26/2019 OFFICIAL RECORD COPY

v t e Letter Sequence Approval
EPID:L-2019-LLA-0010, TSTF-542 (Approved, Closed)
Initiation Request Acceptance... Administration Questions 12 July 2019 Answers 8 August 2019 Results Approval Other:
MONTHYEAR2019-12-26 [Table View]

ML19294A011

Text

SUBJECT:

Dear Mr. Barstow:

Enclosures:

Attachment:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

SUBJECT:

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