Text

Issuance of Amendment Nos. 323, 346, and 306 Regarding Chilled Water Cross-Tie Modification
	ML22273A103
Person / Time
Site:	Browns Ferry
Issue date:	11/22/2022
From:	Kimberly Green; Plant Licensing Branch II
To:	Jim Barstow; Tennessee Valley Authority
	Green K
References
	EPID L-2021-LLA-0203
	Download: ML22273A103 (42)
	v • d • e

November 22, 2022 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. 323, 346, AND 306 REGARDING CHILLED WATER CROSS-TIE MODIFICATION (EPID L-2021-LLA-0203)

Dear Mr. Barstow:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 323, 346, and 306 to Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant (Browns Ferry), Units 1, 2, and 3, respectively. These amendments are in response to your application dated November 5, 2021, as supplemented by letters dated April 6, and August 1, 2022.

The amendments allow the installation and use of a manually operated chilled water cross-tie line between the Browns Ferry, Unit 3, control bay chilled water system and the Browns Ferry, Units 1 and 2 (1/2), control bay chilled water system to be used when both trains of the Unit 1/2 chilled water system are inoperable. The amendments also revise Browns Ferry, Units 1, 2, and 3, Technical Specification 3.8.7, Distribution Systems - Operating, to provide a one-time use exception to the Required Actions during the installation and testing of the cross-tie.

J. Barstow A copy of the Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Kimberly J. Green, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296

Enclosures:

1. Amendment No. 323 to DPR-33

2. Amendment No. 346 to DPR-52

3. Amendment No. 306 to DPR-68

4. Safety Evaluation cc: Listserv

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-259 BROWNS FERRY NUCLEAR PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 323 Renewed License No. DPR-33

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

A. The application for amendment by the Tennessee Valley Authority (the licensee) dated November 5, 2021, as supplemented by letters dated April 6, and August 1, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in Title 10 of the Code of Federal Regulations (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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

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, in part, as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 323, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by David David J. J. Wrona Date: 2022.11.22 Wrona 15:01:30 -05'00' David J. Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: November 22, 2022

ATTACHMENT TO LICENSE AMENDMENT NO. 323 BROWNS FERRY NUCLEAR PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-33 DOCKET NO. 50-259 Replace page 3 of Renewed Facility Operating License No. DPR-33 with the attached revised page 3. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

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 3.8-34 3.8-34 3.8-35 3.8-35 3.8-36 3.8-36 3.8-37 3.8-37

-- 3.8-37a

(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. 323, 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. 323

Distribution Systems - Operating 3.8.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Unit 1 and 2 4.16 kV -------------------NOTE----------------

Shutdown Board Enter applicable Conditions and inoperable, for reasons Required Actions of Condition B, other than &RQGLWLRQ,. C, and F when Condition A results in no power source to a required 480 volt board.

A.1 Restore the Unit 1 and 2 5 days 4.16 kV Shutdown Board to OPERABLE status. AND 12 days from discovery of failure to meet LCO AND A.2 Declare associated diesel Immediately generator inoperable.

(continued)

BFN-UNIT 1 3.8-34 Amendment No. 234, 254,

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One Unit 1 480 V B.1 Restore Board to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Shutdown Board OPERABLE status.

inoperable, for reasons AND other than &RQGLWLRQ,.

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

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

C. One Unit 1 and 2 DG C.1 Restore Unit 1 and 2 DG 5 days Auxiliary Board inoperable. Auxiliary Board to OPERABLE status. AND 12 days from discovery of failure to meet LCO (continued)

BFN-UNIT 1 3.8-35 Amendment No. 234, 254,

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One Unit DC Board D.1 Restore required Board or 7 days inoperable, for reasons other Shutdown Board DC than &RQGLWLRQ,. Distribution Panel to AND OPERABLE status.

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

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

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

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

(continued)

BFN-UNIT 1 3.8-36 Amendment No. 234, 254,

Distribution Systems - Operating 3.8.7 CONDITION REQUIRED ACTION COMPLETION TIME E. Unit 1 and 2 4.16 kV -------------------NOTE----------------

Shutdown Board A and B Enter applicable conditions and inoperable, for reasons required actions of Condition B, other than &RQGLWLRQ,. C, and F when Condition E results in no power source to a OR required 480 volt board.

Unit 1 and 2 4.16 kV Shutdown Board C and D E.1 Restore one 4.16 kV 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable, for reasons Shutdown Board to other than &RQGLWLRQ,. OPERABLE status. AND 12 days from discovery of failure to meet LCO F. One or more required F.1 Declare the affected SGT Immediately Unit 2 or 3 AC or DC or CREV subsystem Boards inoperable, for inoperable.

reasons other than

&RQGLWLRQ,.

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

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

BFN-UNIT 1 3.8-3 Amendment No. 234, 254,

'LVWULEXWLRQ6\VWHPV2SHUDWLQJ

$&7,216 FRQWLQXHG

&21',7,21 5(48,5('$&7,21 &203/(7,21 7,0(

+ 7ZRRUPRUHHOHFWULFDO + (QWHU/&2 ,PPHGLDWHO\

SRZHUGLVWULEXWLRQ VXEV\VWHPVLQRSHUDEOH WKDWUHVXOWLQDORVVRI IXQFWLRQIRUUHDVRQV RWKHUWKDQ&RQGLWLRQ,

127( , 5HVWRUHDIIHFWHGHOHFWULFDO GD\V

2QO\DSSOLFDEOHZKHQWKH SRZHUGLVWULEXWLRQ

FRPSHQVDWRU\DFWLRQVIRU VXEV\VWHPVWR

79$OHWWHU&1/DUH 23(5$%/(VWDWXV

WDNHQHOHFWULFERDUGURRP

WHPSHUDWXUHVDUHPDLQWDLQHG

)DQGRQDRQHWLPH

EDVLVIRULQVWDOODWLRQDQG

WHVWLQJRIWKH8QLW&RQWURO

%D\&KLOOHU&URVVWLHEHIRUH

2FWREHU

, 7ZRRUPRUHHOHFWULFDO SRZHUGLVWULEXWLRQ VXEV\VWHPVLQRSHUDEOH GXHWRLQVWDOODWLRQDQG WHVWLQJRIWKH8QLW

&RQWURO%D\&KLOOHU&URVV

WLH

%)181,7 D $PHQGPHQW1R

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-260 BROWNS FERRY NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 346 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 November 5, 2021, as supplemented by letters dated April 6, and August 1, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in Title 10 of the Code of Federal Regulations (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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.

Enclosure 2

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-52 is hereby amended to read, in part, as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 346, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by David David J. J. Wrona Date: 2022.11.22 Wrona 15:03:03 -05'00' David J. Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: November 22, 2022

ATTACHMENT TO LICENSE AMENDMENT NO. 346 BROWNS FERRY NUCLEAR PLANT, UNIT 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-52 DOCKET NO. 50-260 Replace page 3 of Renewed Facility Operating License No. DPR-52 with the attached revised page 3. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

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 3.8-34 3.8-34 3.8-35 3.8-35

-- 3.8-35a 3.8-36 3.8-36 3.8-37 3.8-37

-- 3.8-37a

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. 346, 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. 346

'LVWULEXWLRQ6\VWHPV2SHUDWLQJ

$&7,216

&21',7,21 5(48,5('$&7,21 &203/(7,21 7,0(

$ 2QH8QLWDQGN9 127(

6KXWGRZQ%RDUG (QWHUDSSOLFDEOH&RQGLWLRQVDQG

LQRSHUDEOHIRUUHDVRQV 5HTXLUHG$FWLRQVRI&RQGLWLRQ%

RWKHUWKDQ&RQGLWLRQ- &'DQG*ZKHQ&RQGLWLRQ$

UHVXOWVLQQRSRZHUVRXUFHWRD

UHTXLUHGYROWERDUG

$ 5HVWRUHWKH8QLWDQG GD\V

N96KXWGRZQ%RDUG

WR23(5$%/(VWDWXV $1'

GD\VIURP

GLVFRYHU\RI

IDLOXUHWRPHHW

/&2

$1'

$ 'HFODUHDVVRFLDWHGGLHVHO ,PPHGLDWHO\

JHQHUDWRULQRSHUDEOH

FRQWLQXHG

%)181,7 $PHQGPHQW1R

'LVWULEXWLRQ6\VWHPV2SHUDWLQJ

$&7,216 FRQWLQXHG

&21',7,21 5(48,5('$&7,21 &203/(7,21 7,0(

% 2QH8QLW9 127(

6KXWGRZQ%RDUG (QWHU&RQGLWLRQ&ZKHQ

LQRSHUDEOHIRUUHDVRQV &RQGLWLRQ%UHVXOWVLQQRSRZHU

RWKHUWKDQ&RQGLWLRQ- VRXUFHWRYROW5029ERDUG

'RU(

25

95029%RDUG$ % 5HVWRUH%RDUGWR LQRSHUDEOHIRUUHDVRQV 23(5$%/(VWDWXV KRXUV

RWKHUWKDQ&RQGLWLRQ-

$1'

25

GD\VIURP

95029%RDUG% GLVFRYHU\RI

LQRSHUDEOHIRUUHDVRQV IDLOXUHWRPHHW

RWKHUWKDQ&RQGLWLRQ- /&2

FRQWLQXHG

%)181,7 $PHQGPHQW1R

'LVWULEXWLRQ6\VWHPV2SHUDWLQJ

$&7,216 FRQWLQXHG

&21',7,21 5(48,5('$&7,21 &203/(7,21 7,0(

& 8QLW95029 & 'HFODUHWKHDIIHFWHG5+5 ,PPHGLDWHO\

%RDUG'LQRSHUDEOHIRU VXEV\VWHPLQRSHUDEOH

UHDVRQVRWKHUWKDQ

&RQGLWLRQ-

25 8QLW95029

%RDUG(LQRSHUDEOHIRU UHDVRQVRWKHUWKDQ

&RQGLWLRQ-

' 2QH8QLWDQG'* ' 5HVWRUH8QLWDQG'* GD\V

$X[LOLDU\%RDUG $X[LOLDU\%RDUGWR

LQRSHUDEOH 23(5$%/(VWDWXV $1'

GD\VIURP

GLVFRYHU\RI

IDLOXUHWRPHHW

/&2

FRQWLQXHG

%)181,7 D $PHQGPHQW1R

'LVWULEXWLRQ6\VWHPV2SHUDWLQJ

$&7,216 FRQWLQXHG

&21',7,21 5(48,5('$&7,21 &203/(7,21 7,0(

( 2QH8QLW'&%RDUG ( 5HVWRUHUHTXLUHG%RDUGRU GD\V

LQRSHUDEOHIRUUHDVRQV 6KXWGRZQ%RDUG'&

RWKHUWKDQ&RQGLWLRQ- 'LVWULEXWLRQ3DQHOWR $1'

23(5$%/(VWDWXV

25 GD\VIURP

GLVFRYHU\RI

2QH8QLWDQG IDLOXUHWRPHHW

6KXWGRZQ%RDUG'& /&2

'LVWULEXWLRQ3DQHO LQRSHUDEOHIRUUHDVRQV RWKHUWKDQ&RQGLWLRQ-

25

9'&5029%RDUG

$LQRSHUDEOHIRU UHDVRQVRWKHUWKDQ

&RQGLWLRQ-

25

9'&5029%RDUG

%LQRSHUDEOHIRU UHDVRQVRWKHUWKDQ

&RQGLWLRQ-

25

9'&5029%RDUG

&LQRSHUDEOHIRU UHDVRQVRWKHUWKDQ

&RQGLWLRQ-

FRQWLQXHG

%)181,7 $PHQGPHQW1R

'LVWULEXWLRQ6\VWHPV2SHUDWLQJ

$&7,216 FRQWLQXHG

&21',7,21 5(48,5('$&7,21 &203/(7,21 7,0(

) 8QLWDQGN9 127(

6KXWGRZQ%RDUG$DQG% (QWHUDSSOLFDEOHFRQGLWLRQVDQG

LQRSHUDEOHIRUUHDVRQVRWKHU UHTXLUHGDFWLRQVRI&RQGLWLRQ%&'

WKDQ&RQGLWLRQ- DQG*ZKHQ&RQGLWLRQ)UHVXOWVLQQR

SRZHUVRXUFHWRDUHTXLUHGYROW

25 ERDUG

8QLWDQGN9 6KXWGRZQ%RDUG&DQG' ) 5HVWRUHRQHN9 KRXUV

LQRSHUDEOHIRUUHDVRQVRWKHU 6KXWGRZQ%RDUGWR

WKDQ&RQGLWLRQ- 23(5$%/(VWDWXV $1'

GD\VIURP

GLVFRYHU\RIIDLOXUH

WRPHHW/&2

2QHRUPRUHUHTXLUHG8QLW * 'HFODUHWKHDIIHFWHG6*7RU ,PPHGLDWHO\

RU$&RU'&%RDUGV &5(9VXEV\VWHP

LQRSHUDEOHIRUUHDVRQVRWKHU LQRSHUDEOH

WKDQ&RQGLWLRQ-

+ 5HTXLUHG$FWLRQDQG + %HLQ02'( KRXUV

DVVRFLDWHG&RPSOHWLRQ7LPHRI

&RQGLWLRQ$%'()RU-QRW $1'

PHW

+ %HLQ02'( KRXUV

, 7ZRRUPRUHHOHFWULFDOSRZHU , (QWHU/&2 ,PPHGLDWHO\

GLVWULEXWLRQVXEV\VWHPV LQRSHUDEOHWKDWUHVXOWLQDORVV RIIXQFWLRQIRUUHDVRQVRWKHU WKDQ&RQGLWLRQ-

%)181,7 $PHQGPHQW1R

'LVWULEXWLRQ6\VWHPV2SHUDWLQJ

$&7,216 FRQWLQXHG

&21',7,21 5(48,5('$&7,21 &203/(7,21 7,0(

127( - 5HVWRUHDIIHFWHGHOHFWULFDO GD\V

2QO\DSSOLFDEOHZKHQWKH SRZHUGLVWULEXWLRQ

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

79$OHWWHU&1/DUH VWDWXV

WDNHQHOHFWULFERDUGURRP

WHPSHUDWXUHVDUHPDLQWDLQHG

)DQGRQDRQHWLPH

EDVLVIRULQVWDOODWLRQDQG

WHVWLQJRIWKH8QLW&RQWURO

%D\&KLOOHU&URVVWLHEHIRUH

2FWREHU

- 7ZRRUPRUHHOHFWULFDO SRZHUGLVWULEXWLRQ VXEV\VWHPVLQRSHUDEOH GXHWRLQVWDOODWLRQDQG WHVWLQJRIWKH8QLW

&RQWURO%D\&KLOOHU

&URVVWLH

%)181,7 D $PHQGPHQW1R

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-296 BROWNS FERRY NUCLEAR PLANT, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 306 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 November 5, 2021, as supplemented by letters dated April 6, and August 1, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in Title 10 of the Code of Federal Regulations (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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.

Enclosure 3

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, in part, as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 306, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by David David J. J. Wrona Date: 2022.11.22 Wrona 15:03:37 -05'00' David J. Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: November 22, 2022

ATTACHMENT TO LICENSE AMENDMENT NO. 306 BROWNS FERRY NUCLEAR PLANT, UNIT 3 RENEWED FACILITY OPERATING LICENSE NO. DPR-68 DOCKET NO. 50-296 Replace page 3 of Renewed Facility Operating License No. DPR-68 with the attached revised page 3. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

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 3.8-37 3.8-37

-- 3.8-37a

(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. 306, 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. 306

'LVWULEXWLRQ6\VWHPV2SHUDWLQJ

$&7,216 FRQWLQXHG

&21',7,21 5(48,5('$&7,21 &203/(7,21

7,0(

) 8QLWN96KXWGRZQ 127(

%RDUG($DQG(% (QWHUDSSOLFDEOHFRQGLWLRQVDQG

LQRSHUDEOH UHTXLUHGDFWLRQVRI&RQGLWLRQ%&

'DQG*ZKHQ&RQGLWLRQ)UHVXOWV

25 LQQRSRZHUVRXUFHWRDUHTXLUHG

YROWERDUG

8QLWN96KXWGRZQ

%RDUG(&DQG(' ) 5HVWRUHRQHN9 KRXUV

LQRSHUDEOH 6KXWGRZQ%RDUGWR

23(5$%/(VWDWXV $1'

GD\VIURP

GLVFRYHU\RIIDLOXUH

WRPHHW/&2

2QHRUPRUHUHTXLUHG * 'HFODUHWKHDIIHFWHG6*7 ,PPHGLDWHO\

8QLWRU$&RU'& RU&5(9VXEV\VWHP

%RDUGVLQRSHUDEOHIRU LQRSHUDEOH

UHDVRQVRWKHUWKDQ

&RQGLWLRQ-

+ 5HTXLUHG$FWLRQDQG + %HLQ02'( KRXUV

DVVRFLDWHG&RPSOHWLRQ

7LPHRI&RQGLWLRQ$% $1'

'()RU-QRWPHW

+ %HLQ02'( KRXUV

, 7ZRRUPRUHHOHFWULFDO , (QWHU/&2 ,PPHGLDWHO\

SRZHUGLVWULEXWLRQ

VXEV\VWHPVLQRSHUDEOH

WKDWUHVXOWLQDORVVRI

IXQFWLRQ

FRQWLQXHG

%)181,7 $PHQGPHQW1R

'LVWULEXWLRQ6\VWHPV2SHUDWLQJ

$&7,216 FRQWLQXHG

&21',7,21 5(48,5('$&7,21 &203/(7,21

7,0(

127( - 5HVWRUHDIIHFWHGHOHFWULFDO GD\V

2QO\DSSOLFDEOHZKHQWKH SRZHUGLVWULEXWLRQ

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

79$OHWWHU&1/DUH VWDWXV

WDNHQHOHFWULFERDUGURRP

WHPSHUDWXUHVDUHPDLQWDLQHG

)DQGRQDRQHWLPH

EDVLVIRULQVWDOODWLRQDQG

WHVWLQJRIWKH8QLW&RQWURO

%D\&KLOOHU&URVVWLHEHIRUH

2FWREHU

- 7ZRRUPRUHHOHFWULFDO SRZHUGLVWULEXWLRQV VXEV\VWHPVLQRSHUDEOH GXHWRLQVWDOODWLRQRIWKH 8QLW&RQWURO%D\&KLOOHU

&URVVWLH

%)181,7 D $PHQGPHQW1R

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 323, 346, AND 306 TO RENEWED FACILITY OPERATING LICENSE 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 November 5, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21309A038), as supplemented by letters dated April 6, and August 1, 2022 (ML22096A328 and ML22213A275, respectively), the Tennessee Valley Authority (TVA, the licensee) submitted to the U.S. Nuclear Regulatory Commission (NRC, the Commission) a license amendment request (LAR) for changes to the Browns Ferry Nuclear Plant (Browns Ferry), Units 1, 2, and 3, updated final safety analysis report (UFSAR) and Technical Specifications (TSs). The requested changes would allow the installation and use of a cross-tie between the Browns Ferry, Unit 3 control bay (CB) chilled water system and the Browns Ferry, Units 1 and 2 (1/2) CB chilled water system. Additionally, the requested changes would revise TS 3.8.7, Distribution Systems - Operating, on a one-time basis, to allow an exception to the Required Actions during the installation and testing of the cross-tie. This would allow the equipment in the Browns Ferry Units 1 and 2 electric board rooms (EBR) to remain operable and would avoid entering multiple TS limiting conditions for operation (LCOs) and their required actions during the installation and testing of the cross-tie and would avoid a three-unit shutdown.

The supplemental letters dated April 6, and August 1, 2022, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on February 22, 2022 (87 FR 9653).

2.0 REGULATORY EVALUATION

2.1 System Description The current design of the Browns Ferry CB chilled water system consists of a shared chilled water system for Units 1 and 2 (Unit 1/2) and a separate system serving Unit 3. The Unit 1/2 chilled water system consist of two 100 percent capacity chilled water pumps and two 100 percent capacity water chilling units that are roof-mounted and air-cooled. The Unit 3 chilled Enclosure 4

water system consists of two 100 percent capacity chilled water pumps and two 100 percent capacity water chilling units with a water-cooled condenser.

The Unit 1/2 CB chilled water system serves nine area air handling units (AHUs):

Units 1 and 2 main control room - two AHUs, 100 percent capacity each

Units 1 and 2 safety-related equipment rooms, Elevation (EL) 593 feet - two AHUs, 100 percent capacity each

Common switchyard relay room, EL 617 feet - one AHU, 100 percent capacity

Unit 1 EBRs - two AHUs, 100 percent capacity each

Unit 2 EBRs - two AHUs, 100 percent capacity each The Unit 3 CB chilled water system serves five AHUs

Unit 3 main control room and office spaces, EL 617 feet - two AHUs, 100 percent capacity

Unit 3 safety-related equipment rooms, EL 593 feet - two AHUs, 100 percent capacity

Common switchyard relay room, EL 617 feet - one AHU, 100 percent capacity For Unit 3, the 480 volt (V) EBR and 4 kilovolt (kV) shutdown board room cooling is independent from the Unit 3 CB chilled water system With the current configuration, the Unit 1/2 CB chillers provide cooling water required to support the operability of the control room air conditioning (A/C), EBR A/C, and 4 kV shutdown boards.

Additionally, the 4 kV shutdown boards are required to support the standby gas treatment system (SGTS) and the control room emergency ventilation (CREV) system. At least one of the Unit 1/2 CB chillers is required to be operable to ensure the operability of their supported equipment. Loss of both Unit 1/2 CB chillers results in declaring the supported systems inoperable and entering LCO 3.8.7 with subsequent entry into LCO 3.0.3, as described in the LAR.

2.2 Licensees Proposed Changes TVA proposes to install a cross-tie line connecting the Unit 3 CB chilled water system to the Unit 1/2 CB chilled water system (Unit 3 CB chiller cross-tie or cross-tie) to be used in the event of an inoperability of both trains of the Unit 1/2 CB chilled water system. The proposed change would involve physical modification of the piping for installation of the cross-tie line connecting the Unit 3 to Unit 1/2 chilled water piping systems. The intent of the modification is to preclude entry into LCO 3.0.3 by crediting the Unit 3 chilled water system when the Unit 1/2 CB chillers are inoperable.

After the proposed installation of the cross-tie, the Unit 3 chilled water system will still supply inventory to its currently supported AHUs to meet Unit 3 demand. However, Unit 3 could also be used to support additional demand for the four Unit 1/2 AHUs for the EBR during cross-tie use.

During use of the cross-tie configuration, Unit 1/2 main control room and safety-related equipment rooms (EL 593 feet) will receive inventory from an alternate emergency direct expansion unit and will not depend on the Unit 3 chilled water system.

The overall completion time requested to complete the installation and testing and to restore the affected electrical power distribution subsystems to OPERABLE status is 9 days, including 2 days for installation and 7 days for testing.

2.2.1 Proposed TS Changes To support the installation of the cross-tie, TVA is requesting a one-time change to the required actions of TS 3.8.7.

The LCO statement for TS 3.8.7 lists the alternating current (AC) and direct current (DC) electrical power distribution equipment required to be OPERABLE during MODES 1, 2 and 3 (i.e., power operation, startup, and hot shutdown, respectively). The ACTIONS table in TS 3.8.7 contains Conditions, Required Actions, and associated Completion Times (CTs) for instances when the LCO is not met. The licensee proposed changes to Conditions, Required Actions, and CTs in the ACTIONS table of TS 3.8.7 for situations when the LCO would not be met due to the installation and testing of the cross-tie. The changes would add a new one-time use Condition related to the cross-tie installation and testing as well as TS changes that provide exceptions to the existing Condition descriptions of TS 3.8.7. During the NRC staffs review, the licensee modified the initially proposed changes to the TSs. The final version of the licensees proposed changes is contained in Attachment 2 to the supplemental letter dated August 1, 2022 (ML22213A275).

2.2.1.1 Proposed New Browns Ferry, Unit 1, TS 3.8.7 Condition I and Changes to Conditions A, B, D, E, F, G and H The licensee proposed adding a new Condition I to the Browns Ferry, Unit 1, ACTIONS table, as follows.

CONDITION REQUIRED ACTION COMPLETION TIME

NOTE--------------- I.1 Restore affected electrical power 9 days Only applicable when the distribution subsystems to compensatory actions for OPERABLE status.

TVA letter CNL-21-020 are taken, electric board room temperatures are maintained 104°F, and on a one-time basis for installation and testing the Unit 3 Control Bay Chiller Cross-tie before October 1, 2025.

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

The licensee proposed adding the phrase , for reasons other than Condition I to the end of each Condition description in Conditions A, B, D, E, F and H. The licensee also proposed rewording the Condition G description from Required Action and associated Completion Time

of Condition A, B, C, D or E not met. to Required Action and associated Completion Time of Condition A, B, C, D, E, or I not met.

2.2.1.2 Proposed New Browns Ferry, Unit 2, TS 3.8.7 Condition J and Changes to Conditions A, B, C, E, F, G, H, and I The licensee proposed similar changes as to those proposed for the Browns Ferry, Unit 1 TSs but lettered the proposed new Condition J to account for existing Conditions in the Unit 2 ACTIONS table. New Condition J would appear as follows.

CONDITION REQUIRED ACTION COMPLETION TIME

NOTE--------------- J.1 Restore affected electrical power 9 days Only applicable when the distribution subsystems to compensatory actions for OPERABLE status.

TVA letter CNL-21-020 are taken, electric board room temperatures are maintained 104°F, and on a one-time basis for installation and testing the Unit 3 Control Bay Chiller Cross-tie before October 1, 2025.

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

The licensee proposed adding the phrase , for reasons other than Condition J to the end of each Condition description in Conditions A, B, C, E, F, G, and I. The licensee also proposed rewording the Condition H description from Required Action and associated Completion Time of Condition A, B, D, E, or F not met. to Required Action and associated Completion Time of Condition A, B, D, E, F, or J not met.

2.2.1.3 Proposed New Browns Ferry, Unit 3, TS 3.8.7 Condition J and Changes to Conditions G and H The licensee proposed similar changes as to those proposed for the Browns Ferry, Unit 1 TSs but lettered the proposed new Condition J to account for existing Conditions in the Unit 3 ACTIONS table. New Condition J would appear as follows.

CONDITION REQUIRED ACTION COMPLETION TIME

NOTE--------------- J.1 Restore affected electrical power 9 days Only applicable when the distribution subsystems to compensatory actions for OPERABLE status.

TVA letter CNL-21-020 are taken, electric board room temperatures are maintained 104°F, and on a one-time basis for installation and testing the Unit 3 Control Bay Chiller Cross-tie before October 1, 2025.

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

The licensee proposed adding the phrase , for reasons other than Condition J to the end of the Condition G description. The licensee also proposed rewording the Condition H description from Required Action and associated Completion Time of Condition A, B, D, E, or F not met. to Required Action and associated Completion Time of Condition A, B, D, E, F, or J not met.

2.2.2 Proposed UFSAR Changes The licensee proposed to revise Browns Ferry UFSAR, section 10.12, HVAC Systems, and Appendix F, Unit Sharing and Interactions, to reflect the design modification and to incorporate licensing basis changes describing the Unit 3 CB chilled water system as both a shared system and as an alternate chilled-water source for Unit 1 and Unit 2 EBR AHUs.

Section 10.12 of the UFSAR would be revised to identify that upon loss of both Unit 1/2 CB chillers, supplemental cooling is provided via a cross-tie connecting the Unit 3 CB chilled water system to the Unit 1 and Unit 2 EBR AHUs.

Section F.7.11 of Appendix F to the UFSAR would be revised to identify that the Unit 3 CB chilled water system is shared in that it can supply chilled water to the Unit 1 and Unit 2 EBR AHUs if needed.

2.3 Regulatory Review The NRC staff reviewed the licensees application to determine whether (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 the activities proposed will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or the health and safety of the public. The NRC staff considered the following regulatory requirements, guidance, and licensing and design-basis information during its review of the proposed changes.

Section 50.36, Technical specifications, of Title 10 of the Code of Federal Regulations (10 CFR) establishes the regulatory requirements related to the content of TSs.

Paragraph (a)(1) of 10 CFR 50.36 requires an application for an operating license to include proposed TSs. 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.

Paragraph (b) of 10 CFR 50.36 requires TSs to be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to 10 CFR 50.34.

Paragraph (c)(2) of 10 CFR 50.36 states that LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility, and when an LCO is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the LCO can be met.

Browns Ferry, Units 1, 2, and 3, TS 1.3, Completion Times, establishes the completion time (CT) convention and provides guidance for its use. Usage rules for LCOs are in TS 3.0, Limiting Condition for Operation (LCO) Applicability. Per TS LCO 3.0.2, Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met While Browns Ferry TSs 1.0 and 3.0 are not regulations, they constitute license requirements imposed on plant operation.

Part 50, Domestic Licensing of Production and Utilization Facilities, of 10 CFR, Appendix A, General Design Criteria [GDC] for Nuclear Power Plants, Criterion 5, Sharing of structures, systems, and components, provides that Structures, systems, and components important to safety shall not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units.

The Browns Ferry units were designed and constructed based on the proposed GDC published by the Atomic Energy Commission (AEC) on July 11, 1967. Appendix A of the Browns Ferry UFSAR (ML21286A200) identifies the AEC GDC and the UFSAR sections that describe the plants conformance to the GDC. Previously, the NRC staff determined that draft GDC 4 is equivalent to current GDC 5 regarding the sharing of systems and components (ML17032A120).

The NRC staffs guidance for the review of TSs is in Chapter 16, Revision 3, Technical Specifications, of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (SRP), dated March 2010 (ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared Standard

Technical Specifications (STSs) for each of the light-water reactor nuclear designs. The STS applicable to Browns Ferry are, Standard Technical Specifications, General Electric BWR/4 Plants, NUREG-1433, Volume 1, Specifications, and Volume 2, Bases, Revision 5.0, dated September 2021 (ML21272A357 and ML21272A358, respectively). Chapter 16 of NUREG-0800 specifies that the staff reviews proposed TSs for whether the content and format of the proposed TSs are consistent with the applicable STS. Where TS provisions depart from the reference STSs, the NRC staff is to determine whether the proposed differences are justified by uniqueness in plant design or other considerations.

3.0 TECHNICAL EVALUATION

The NRC staff evaluated the licensees application to determine if the proposed changes are consistent with the regulations, guidance, and plant-specific design and licensing basis information discussed in section 2.3 of this safety evaluation. The staff also reviewed the licensees justifications for the proposed changes.

3.1 Staff Evaluation of Proposed Cross-Tie The requested amendments would support the installation of a manually operated cross-tie pipe between the Browns Ferry, Unit 3, CB chilled water system and the Browns Ferry, Unit 1/2 CB chilled water system supplying the EBR AHUs. To provide an alternative means of protection for the electrical equipment in the Units 1 and 2 EBRs against the failure of both Unit 1/2 chillers, the cross-tie to the Unit 3 CB chilled water system could be engaged to provide an alternative source of chilled water for cooling. The use of the cross-tie would support the operability of the Browns Ferry, Units 1 and 2 EBR A/C systems and their supported electrical equipment.

The function of the CB ventilation and A/C systems is to maintain the temperature of the main control room (MCR) and EBR within the acceptable limits for operation of instruments and for uninterrupted safe occupancy under all plant conditions. Section 10.12.5.3 of the Browns Ferry UFSAR describes the supplementary cooling that is provided to prevent overheating of essential electrical equipment as a result of loss of cooling due to failure of both water chillers serving Units 1 and 2, or by the rupture of the chilled water loops. Two 100 percent capacity chilled water pumps support both Unit 1 and Unit 2 AHU demand, and two separate 100 percent capacity water chilling units support the Unit 3 demands.

With this current configuration, heat loads for the Unit 1/2 CB chilled water system are independent and isolated from the Unit 3 CB chilled water system. In the event that both trains of the Unit 1/2 CB chilled water system are inoperable, emergency backup cooling is provided to the Units 1 and 2 MCR and the safety-related equipment along the elevation 593 feet hallway.

However, no backup cooling is available for the Unit 1 and Unit 2 EBRs. As a result, if a Unit 1 and/or Unit 2 EBR AHU(s) loses cooling, the chilled water system is declared inoperable and supported electrical equipment in the affected EBR(s) must also be declared inoperable.

With the proposed cross-tie configuration, heat loads for the Unit 1/2 CB chilled water system remain independent and isolated from the Unit 3 CB chilled water system during normal operation. Installation of the cross-tie enables the use of the Unit 3 chillers for cooling its AHUs and Unit 1 and Unit 2 EBR AHUs. The licensees proposed UFSAR changes would define the cross-tie use as providing an alternative means of protection for Units 1 and 2 EBRs against failure of both Unit 1/2 chillers.

3.1.1 Evaluation of Use of the Cross-Tie Configuration According to the licensee, the use of the cross-tie would result in the ability to share chilled water function between the three Browns Ferry units. General Design Criterion 5 requires structures, systems, and components important to safety to not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units.

During normal operation, the cross-tie is not proposed to be used and would be isolated by manual valves. As indicated in the LAR, the alignment of the cross-tie involves manual manipulation of several valves that are accessible in the control building in order to serve Unit 1 and Unit 2 EBR AHUs. This valve manipulation is like swapping chiller trains or the local startup of the emergency CB chiller unit. Inadvertent opening of these manual isolation valves is minimized by requiring multiple actions by an operator for four manual valves. Therefore, isolation of the cross-tie precludes the units from impairing the ability of other unit functions during normal operation.

After installation of the proposed cross-tie, the use of the cross-tie would allow the Unit 1 and Unit 2 EBR AHUs to remain operable and continue performing their safety function. When required, the units coordinate an implementation plan in accordance with Browns Ferry operating instructions. The Unit 1 or Unit 2 MCR would inform the Unit 3 MCR that both Unit 1/2 CB chillers are inoperable, and that implementation of the cross-tie is required.

As described in the LAR, the use of the cross-tie would be limited per TS to only 7 days of operation in that configuration. In the event of inoperable Unit 1/2 chillers, the Unit 1 and Unit 2 EBR AHUs would remain OPERABLE via cross-tie use. However, the Units 1 and 2 MCR A/C systems are not serviced by the cross-tie and TS LCO 3.7.4 would be entered and MCR A/C systems would be inoperable. Condition B of TS LCO 3.7.4 requires actions with two Unit 1/2 MCR A/C subsystems inoperable to immediately initiate action to restore one Units 1 and 2 MCR A/C subsystem to OPERABLE status, to place an alternate method of MCR cooling in operation within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and to restore one MCR A/C subsystem to OPERABLE status within 7 days. Once Unit 1/2 chiller operability is restored, the cross-tie would no longer be needed.

In the cross-tie use configuration, the Unit 3 CB chilled water system must provide adequate heat removal capability for its safety-related heat loads in addition to those for cooling the Unit 1 and Unit 2 EBRs. The licensee evaluated the capacity of the Unit 3 chiller to meet its current demands and the added demand of cross-tie related systems. The rated capacity of each Unit 3 chiller including fouling factors is 112.5 tons. The current design basis heat loads on the Unit 3 chiller total 74 tons, and the additional design basis heat loads from Unit 1 and Unit 2 EBRs would increase the design requirement to 105.3 tons. The licensee indicated that approximately 7.2 tons of excess heat removal capacity is available. Thus, the additional cross-tie cooling demands can be met by the Unit 3 chillers alone, in addition to the normal Unit 3 cooling demands. The licensee stated that a reduction in design margin for the Unit 3 CB chilled water system as a result of the design basis heat loads from the Unit 1 and Unit 2 EBR AHUs would not impair the ability of Unit 3 to safely shut down or maintain it in a safe shutdown condition.

The Unit 3 chiller performance and capacity are verified via current TS Surveillance Requirement (SR) 3.7.4.1. The procedures implementing this SR ensure that the Unit 3 MCR A/C system has the capability to remove the assumed heat load to maintain the required environmental conditions for plant operators and safety-related control equipment by verifying

proper chilled water temperatures and chilled water flows. The licensee indicated that the procedures verify that the heat removal capability of the system is sufficient to remove the MCR heat load assumed in the safety analyses. The licensee indicated that the SR testing and calculation processes would be revised as necessary to include the additional heat loads imposed by the Unit 1 and Unit 2 EBRs AHUs via the proposed cross-tie.

The addition of the cross-tie would not result in a reduction of system or equipment redundancy, diversity, separation, or independence from the current design. The cross-tie would allow a defense-in-depth feature to support the operability of the Unit 1 and Unit 2 EBRs cooling by providing an alternative source of chilled water if both trains of the Unit 1/2 chilled water system are unavailable.

As indicated in the LAR, the use of the cross-tie would be for cooling Unit 1 and Unit 2 EBRs in the event of Unit 1/2 CB chiller inoperability. Cross-tie use for cooling other AHUs supported by the Unit 1/2 CB chilled water system has not been evaluated in this safety evaluation. If use of the cross-tie is required, the Units 1 and 2 MCR and Safety-Related Equipment Room (EL 593 feet) will receive cooling from an alternate emergency direct expansion unit and will not depend on the Unit 3 CB chilled water system.

Based on the proposed configuration and use of the cross-tie discussed above, the NRC staff finds that the use of the cross-tie as an alternative cooling source for the Browns Ferry, Unit 1 and Unit 2 EBR AHUs is acceptable for maintaining safety of the plant in the event that the Unit 1/2 CB chillers are inoperable and that the proposed modification will continue to meet the intent of GDC 5.

3.1.2 Evaluation of Chiller Use During Installation and Testing To support the installation and testing of the proposed cross-tie, the licensee is requesting a one-time use TS change that provides an exception to the Required Actions of TS 3.8.7. This TS is related to the electric power distribution systems located within the EBRs that are cooled by the Unit 1/2 CB chilled water system. The proposed exception would allow the equipment in the Unit 1 and Unit 2 EBRs to remain operable during the installation and testing and to avoid a three-unit shutdown, which would otherwise be required. The licensee requests a completion time of 9 days for this exception, 2 days of which would allow for the installation so that essential cooling to the EBR AHUs could be temporarily isolated to complete the proposed cross-tie connections to the Unit 3 CB chilled water piping.

Connecting the Unit 3 CB chilled water system to the Unit 1 and Unit 2 EBR AHUs would require temporarily isolating the EBR AHUs from the Unit 1/2 CB chilled water system. During this evolution, the Unit 1/2 chillers would remain OPERABLE and would continue to supply chilled water to the Units 1 and 2 MCR AHUs and the EL 593 feet AHUs. The AHUs impacted by the installation would be the cooling for the Unit 1 and Unit 2 EBRs.

The licensee estimated that total installation would last 43 hours4.976852e-4 days 0.0119 hours 7.109788e-5 weeks 1.63615e-5 months based on the estimated work steps required to install and leak check the prepared piping spool sections at the Units 1 and 2 chilled water piping. The licensee indicated that during the installation, the piping to the EBR AHUs would be open to the atmosphere for approximately 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months and available for use within 20 to 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months after opening the system. The licensee performed a GOTHIC code analysis for the CB and EBR, which assumed a total loss of EBR cooling in Unit 1 or 2. Based on this analysis, the most limiting EBR heat up rate is 23.27 hours3.125e-4 days 0.0075 hours 4.464286e-5 weeks 1.02735e-5 months before reaching the design operating limit of 104 degrees Fahrenheit. Therefore, the duration of the system in a loss-of-function (open

to environment) condition would be less than the calculated time to reach the 104 degrees Fahrenheit maximum limit of EBR temperature.

The GOTHIC code analysis is described in the licensees response to NRC staff request for additional information STSB RAI 2. For the case modeling a non-accident condition (a loss of Unit 1 and Unit 2 EBR A/C, with Unit 1 and 2 EBR normal heat loads, reactor building at 75 degrees Fahrenheit, and outdoor ambient and wall conditions at 75 degrees Fahrenheit), the limiting EBR reaches a temperature of 100.22 degrees Fahrenheit after 1000 hours0.0116 days 0.278 hours 0.00165 weeks 3.805e-4 months . Thus, exceeding the design limit of 104 degrees Fahrenheit during the installation of the cross-tie is not considered credible. For the case modeling the accident condition (a loss of Unit 1 and Unit 2 EBR A/C, with the EBR doors closed, and reactor building at 127 degrees Fahrenheit), the limiting EBR reaches the design temperature of 104 degrees Fahrenheit after 23.27 hours3.125e-4 days 0.0075 hours 4.464286e-5 weeks 1.02735e-5 months .

After installation and reconnection of the cross-tie piping, flow-balancing the system would be required with the Unit 3 chiller cross-tie aligned to the Unit 1 and Unit 2 EBR AHUs. During this time, Unit 1 and Unit 2 EBR AHUs and the aligned Unit 3 CB chilled water system train would be available but would not be OPERABLE. The licensee indicated that the standby Unit 3 CB chilled water system train (the train not being flow-balanced at the time) and both Unit 1/2 CB chilled water system trains would remain OPERABLE. The licensee stated that there would be ample time to realign the systems to their normal configurations in the event that cooling is needed during the testing and flow-balancing phase.

The licensee included compensatory actions in TVA letter CNL-21-020 (ML21309A038), which is referenced in the TS notes proposed to be added to the applicable conditions within TS LCO 3.8.7. These compensatory actions are (1) removal of missile hazards, (2) no work allowed in the switchyard or transformer yard, (3) no planned electrical system AC or DC work will be authorized, (4) in the case of severe weather, monitor plant areas for flying debris hazards every shift, in accordance with plant procedures, (5) maintain one train of the Unit 1/2 CB chillers in operation, and (6) no hot work in the plant and no high-risk activities during the installation period.

To ensure that the Unit 1 and Unit 2 EBRs do not reach temperatures beyond their design limit, the licensees compensatory actions require monitoring temperatures during the cross-tie installation. Specifically, the licensee will monitor the ambient air temperature in the 1A, 1B, 2A, and 2B EBRs and their associated 480 V shutdown board rooms twice per shift and document the temperatures in the narrative logs. If the temperatures in these board rooms exceed 100 degrees Fahrenheit, the licensee will open the associated EBR doors and install fans to assist in maintaining the associated temperatures below 100 degrees Fahrenheit. The compensatory action of opening the EBR doors and installing temporary fans is a risk management activity established for defense-in-depth during the installation of the cross-tie.

The NRC staff finds that the compensatory actions referenced by the proposed new TS conditions adequately address those actions needed during the installation of the cross-tie and are of an appropriate scope to minimize the likelihood of needing the chiller units and retain the ability to realign the systems to their normal configurations in the event that cooling is needed.

3.1.3 Technical Conclusion for the Use of the Cross-Tie and Chiller Use During Testing and Installation Based on the discussion above, including the compensatory actions referred to in the Note within proposed new TS 3.8.7, Conditions I and J, the NRC staff concludes that the risk will be

minimized and that reasonable controls will be in place to retain the ability to perform chiller design functions during the proposed installation and flow-balancing of the chilled water system.

Therefore, the NRC staff finds acceptable, on a one-time basis, for the CB chilled water system to be inoperable for up to 9 days for the purpose of installation and flow-balancing. Based on the revised configuration with the cross-tie discussed above, the staff also finds the use of the new cross-tie as an alternative cooling source acceptable, and that the CB chilled water system will continue to meet the intent of GDC 5.

3.2 Evaluation of Proposed Technical Specifications Changes 3.2.1 Evaluation of Completion Time for Proposed New Conditions I and J In the LAR, the licensee proposed a total of 9 days for the installation and testing of the cross-tie modification between the Browns Ferry Unit 1/2 CB chilled water system, supplying the Unit 1 and Unit 2 EBR AHUs, and the Browns Ferry, Unit 3 CB chilled water system. The licensee proposed to add new Conditions I and J to Browns Ferry, Units 1, 2, and 3, TS 3.8.7, with a 9-day CT to reflect the exception to Unit 1 TS 3.8.7, Conditions A, B, D, E, F, G, and H; Unit 2, TS 3.8.7, Conditions A, B, C, E, F, G, H, and I; and Unit 3, TS 3.8.7, Conditions G and H. In section 2.2 of the LAR, the licensee stated, in part, that the installation of the cross-tie is expected to last 43 hours4.976852e-4 days 0.0119 hours 7.109788e-5 weeks 1.63615e-5 months based on the estimated work steps required to install and leak check the prepared piping spool sections at the Units 1 and 2 chilled water piping. Section 3.0 of the LAR states, in part:

Current analysis indicates that the Unit 1 and Unit 2 EBRs will not reach the design operating limit of 104°F for approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during a design-basis accident when no cooling is provided to the EBRs, the doors are closed, and the reactor building is already at 127°F. During the 43-hour cross-tie installation, the piping to the EBR AHUs will be open to the atmosphere for approximately 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months and available for use within 20 to 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months after opening the system. This includes connecting both the supply and return lines to the cross-tie. This is less than the approximate 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the EBRs to heat up to 104°F when no action is taken to provide cooling to the rooms The LAR proposed an additional 7 days for flow-balancing (i.e., testing) the system with the cross-tie aligned to the Unit 1 and Unit 2 EBR AHUs. Section 3.0 of the LAR states that during the time for flow-balancing of the system, the Unit 1 and Unit 2 EBR AHUs and the aligned Unit 3 CB chilled water system train will be available but will not be OPERABLE because chilled water flow to the EBR AHUs and other Unit 3 CB chilled water system loads is varying while it is adjusted to design values.

In its supplemental letter dated August 1, 2022, in response to NRC staff request for additional information EEEB RAI 1, the licensee explained that the proposed 7 days for testing/flow-balancing the system was estimated based on the time needed to perform Unit 3 SRs and several iterations of flow-balancing the system to ensure that both Unit 3 trains have adequate flow to support cooling of the heat loads and that each Unit 1 and Unit 2 AHU has the required flow rate and to correct any equipment issues that may arise (e.g., flow-balancing valves). In addition, the licensee stated that the proposed 9-day exception to the Units 1, 2, and 3, TS 3.8.7 requirements would be applicable when the compensatory actions of TVA letter CNL-21-020

(ML21309A038), as described in section 3.0 the LAR, would be taken and that the EBR temperatures would be maintained less than or equal to 104 degrees Fahrenheit.

In its supplemental letter dated August 1, 2022, in response to NRC staff request for additional information EEEB RAI 2, the licensee stated that the 104 degrees Fahrenheit EBR design temperature is described in the Browns Ferry Technical Requirements Manual Bases for Technical Requirement 3.7.6, Electric Board Room AC System, which was provided to the NRC in a letter dated September 4, 2003 (ML032580134).

The NRC staff finds that because the proposed 9-day exception to the affected Units 1, 2, and 3 TS 3.8.7 requirements is based on the estimated work steps, plant procedures, and valve manipulations required for installing and flow-balancing the cross-tie configuration, and because actions will be taken during the 9 days to ensure that the EBR temperatures do not exceed the design operating limit of 104 degrees Fahrenheit, the proposed CT of 9 days for proposed Conditions I and J is acceptable.

3.2.2 Proposed New Conditions I (Unit 1) and J (Units 2 and 3).

The licensee provided a justification for the proposed new Conditions. The NRC staff reviewed the proposed changes along with the licensees justifications. On page E2 of its supplemental letter dated April 6, 2022, the licensee provided clarification on when the compensatory measures referenced in the proposed NOTE would be taken. On page E2 of its supplemental letter dated August 1, 2022, the licensee provided clarification on how the plant operators would respond if the compensatory measures referenced in the NOTE were not taken or found to be not taken during the installation of the cross-tie and stated:

TVA confirms that the proposed language being added to the NOTE for Conditions I (Browns Ferry Nuclear Plant (BFN) Unit 1) and J (BFN Units 2 and 3), as modified by Attachment 2 of this letter, means that if the compensatory actions of TVA letter CNL-21-020 are not taken (or found to be not taken) during installation of the Unit 3 control bay chiller cross-tie, then the associated Conditions, Required Actions, and Completion Times for the applicable Conditions would apply.

The NRC staff reviewed this information and determined that the compensatory measures and plan to implement them are acceptable.

On page E3 of its supplemental letter dated August 1, 2022, the licensee provided clarification on the justification for the temperature limit in the proposed NOTE for new Conditions I and J, as well has how plant operators would respond to a situation where the temperature limit in the NOTE would be exceeded and stated:

In this manner, if the 104°F EBR design temperature is exceeded, the exceptions for Condition I and J will no longer apply for Conditions H (Unit 1) and I (Unit 2) and TS 3.0.3 will immediately be entered.

The NRC staff determined that the NOTE is appropriate because it provides detail on when the new Conditions I and J would apply and incorporates by reference the compensatory measures that must be in place during the Condition.

On pages E4 and E5 of the LAR, the licensee provided a description of the planned time needed to install the cross-tie, as well as the planned time to complete testing. The licensee stated that the 9-day CT was needed to allow for a 2-day period for cross tie installation and a 7-day period for testing. As described in section 3.2.1 of this safety evaluation, the NRC staff determined that the licensee provided adequate justification for the 9-day CT to restore the affected systems to OPERABLE status. The NRC staff determined that the stipulations in the NOTE as well as the Required Actions of Conditions I (Unit 1) and J (Units 2 and 3) along with existing usage rules in the Browns Ferry TSs will continue to provide acceptable remedial actions until the LCOs can be met because, as described by the licensee on pages E2 and E3 of the supplemental letter dated August 1, 2022, if the stipulations are not met, the usage rules will require the licensee to enter the more restrictive existing Conditions, or shutdown.

3.2.3 Adding Exceptions to Existing Conditions The licensee provided a justification for the proposed changes to add exceptions to selected existing Conditions in Browns Ferry TS 3.8.7. The NRC staff determined that the addition of the exceptions is acceptable because the proposed changes properly revise the TSs to account for the one-time change to allow the installation and testing of the cross-tie while the Units are in MODES 1 through 3. The NRC staff determined that the existing usage rules in the Browns Ferry TSs will continue to provide assurance that the revised Conditions will be properly applied.

3.2.4 Comparison to NUREG-1433 The NRC staff reviewed the proposed TS changes and the licensees justifications for the changes in the LAR, as supplemented. The staff determined that the proposed TS changes represent a departure from the format and content for TSs found in NUREG-1433. Per Chapter 16 of NUREG-0800, such departures require special attention to determine whether proposed differences are justified by uniqueness in plant design or other considerations so that 10 CFR 50.36 is met. The staff determined that the CB chilled water system connection design, both existing and proposed, represents a uniqueness in plant design that justifies the differences between the proposed Browns Ferry TSs and NUREG-1433. As described above, the staff finds this design to be acceptable.

3.2.5 Technical Conclusion for Proposed TS Changes The regulation at 10 CFR 50.36(a)(1) states, in part, A summary statement of the bases or reasons for such specifications shall also be included in the application, but shall not become part of the technical specifications. The licensee provided the bases or reasons for the proposed changes to Browns Ferry TS 3.8.7.

The regulation at 10 CFR 50.36(b) requires that TSs be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto. The licensee provided an evaluation and justification of the proposed changes to Browns Ferry, Units 1, 2, and 3, TS 3.8.7.

The NRC staff reviewed the proposed changes as well as the licensees justifications for the changes. The staff has determined that the licensee has met the requirements of 10 CFR 50.36(a)(1) because a summary statement of the reasons for the TSs, as amended, was provided. The staff has also determined that the licensee will continue to meet the regulatory requirements of 10 CFR 50.36(b) because the TSs, as amended, will continue to be derived from the analyses and evaluation included in the safety analysis report, and amendments

thereto. The staff has determined that the licensee will continue to meet the regulatory requirements of 10 CFR 50.36(c)(2) because the LCO, as amended, will continue to describe the lowest functional capability or performance level of equipment required for safe operation of the facility and the remedial actions permitted by the TSs until the LCO can be met (in this case, the information in the ACTIONS table) have been deemed acceptable to the staff. Finally, while the format and content of the proposed changes do not conform to the guidance in NUREG-1433, the licensee provided adequate justification for the proposed changes. Therefore, the NRC staff finds that the proposed changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Alabama State official was notified of the proposed issuance of the amendments on September 15, 2022. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. 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 NRC has previously issued a proposed finding that the amendments involve no significant hazards consideration in the Federal Register on February 22, 2022 (87 FR 9653), 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 Commissions 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.

Principal Contributors: G. Curran, NRR A. Foli, NRR V. Goel, NR M. Hamm, NRR Date: November 22, 2022

ML22273A103 OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NRR/DSS/SCPB/BC NRR/DEX/EEEB/BC NAME KGreen RButler BWittick MWendell DATE 09/29/22 10/04/22 8/26/22 9/2/22 OFFICE NRR/DSS/STSB/BC OGC - NLO w/edits NRR/DORL/LPL2-2/BC NRR/DORL/LPL2-2/PM NAME VCusumano KDowling DWrona KGreen DATE 9/14/22 10/24/22 11/22/22 11/22/22

v t e Letter Sequence Approval
EPID:L-2021-LLA-0203, (Approved, Closed)
Initiation Acceptance, Acceptance Supplement, Supplement Administration Questions Answers Results Approval Other: CNL-21-020, Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie Modification to Support System Operability (BFN-TS-518), ML22168A080
MONTHYEAR2022-11-22 [Table View]

ML22273A103

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

Navigation menu

Search