Text

License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423-A, Revision 1, Technical Specifications End States, NEDC-32988-A, Using the Consolidated Line.
	ML25100A124
Person / Time
Site:	Browns Ferry
Issue date:	04/10/2025
From:	Hulvey K; Tennessee Valley Authority
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	CNL-25-041
	Download: ML25100A124 (1)
	v • d • e

1101 Market Street, Chattanooga, Tennessee 37402 10 CFR 50.90 CNL-25-041 April 10, 2025 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296

Subject:

Browns Ferry Nuclear Plant, Units 1, 2, and 3 - License Amendment Request for Adoption of Technical Specifications Task Force (TSTF)

Traveler TSTF-423-A, Revision 1, "Technical Specifications End States, NEDC-32988-A," Using the Consolidated Line Item Improvement Process (BFN-TS-548)

In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.90, Tennessee Valley Authority (TVA) is submitting a request for an amendment to Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3 Technical Specifications (TS) to incorporate the Nuclear Regulatory Commission (NRC)-approved TSTF-423-A, Revision 1.

The proposed amendment would modify TS to risk-inform requirements regarding selected Required Action end states by incorporating the boiling water reactor (BWR) owners group (BWROG) approved Topical Report NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required Action End States for BWR Plants.

Additionally, the proposed amendment would modify the TS Required Actions with a Note prohibiting the use of limiting condition for operation (LCO) 3.0.4.a when entering the preferred end state (Mode 3) on startup.

provides a description and assessment of the proposed change, the requested confirmation of applicability, and plant-specific verifications.

.1 to Enclosure 1 provides markup pages of existing BFN Unit 1 TS to show the proposed change.

.2 to Enclosure 1 provides markup pages of existing BFN Unit 2 TS to show the proposed change.

.3 to Enclosure 1 provides markup pages of existing BFN Unit 3 TS to show the proposed change.

U.S. Nuclear Regulatory Commission CNL-25-041 Page 2 April 1, 2025 to Enclosure 1 provides markup pages of existing BFN Unit 1 TS Bases to show the proposed change (BFN Units 2 and 3 changes will be similar). Changes to the existing TS Bases are provided for information only and will be implemented under the Technical Specification Bases Control Program.

summarizes the regulatory commitments made in the submittal.

TVA requests approval of the proposed license amendment within 6 months of completion of the NRCs acceptance review, with the amendment being implemented within 90 days.

In accordance with 10 CFR 50.91(a)(1), Notice for public comment, the analysis regarding the issue of no significant hazards consideration (NSHC) using the standards in 10 CFR 50.92 is being provided to the Commission in accordance with the distribution requirements in 10 CFR 50.4.

In accordance with 10 CFR 50.91(b)(1), State consultation, a copy of this application and the reasoned analysis regarding NSHC is being provided to the designated Alabama official.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 1th day of April 2025.

Please address any questions regarding this submittal to Amber V. Aboulfaida, Senior Manager, Fleet Licensing, at avaboulfaida@tva.gov.

Respectfully, Kimberly D. Hulvey General Manager, Nuclear Regulatory Affairs & Emergency Preparedness

Enclosures:

1.

Description and Assessment of the Proposed Change 2.

List of Regulatory Commitments cc (Enclosures):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant State Health Officer, Alabama Department of Public Health Digitally signed by Edmondson, Carla Date: 2025.04.10 10:18:36 -04'00' CNL-25-041 E1 - 1 of 11 Description and Assessment of the Proposed Change

Subject:

Browns Ferry Nuclear Plant, Units 1, 2, and 3 - License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423-A, Revision 1, "Technical Specifications End States, NEDC-32988-A," Using the Consolidated Line Item Improvement Process CONTENTS

1.0 DESCRIPTION

................................................................................................................... 2

2.0 ASSESSMENT

................................................................................................................... 2 2.1 Applicability of Topical Report NEDC-32988-A, TSTF-423-A, and Model Safety Evaluation.................................................................................................................................. 2 2.2 Optional Changes and Variations................................................................................... 2

3.0 REGULATORY ANALYSIS

................................................................................................ 9 3.1 No Significant Hazards Consideration Determination.................................................... 9 3.2 Verifications, Commitments, and Additional Information Needed................................. 10 4.0 ENVIRONMENTAL EVALUATION.................................................................................. 11

5.0 REFERENCES

................................................................................................................. 11 Attachments:

1.1 Proposed TS Changes (Markups) for BFN Unit 1 1.2 Proposed TS Changes (Markups) for BFN Unit 2 1.3 Proposed TS Changes (Markups) for BFN Unit 3 2.

Proposed TS Bases Changes (Markups) for BFN Unit 1 (For Information Only)

CNL-25-041 E1 - 2 of 11 Description and Assessment of the Proposed Change

1.0 DESCRIPTION

The proposed amendment would modify technical specifications (TS) to risk-inform requirements regarding selected Required Action end states. Additionally, it would modify the TS Required Actions with a Note prohibiting the use of limiting condition for operation (LCO) 3.0.4.a when entering the preferred end state (Mode 3) on startup. The changes are consistent with Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) traveler TSTF-423-A, Revision 1, Technical Specifications End States, NEDC-32988-A, dated December 22, 2009 (ADAMS Accession Number ML093570241)

(Reference 1). The Federal Register notice published on February 18, 2011 (76 FR 9614)

(Reference 2) announced the availability of this TS improvement as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT

2.1 Applicability of Topical Report NEDC-32988-A, TSTF-423-A, and Model Safety Evaluation Tennessee Valley Authority (TVA) has reviewed boiling water reactor (BWR) owners group (BWROG) topical report (TR) NEDC-32988-A (Reference 3), TSTF-423, Revision 1 (Reference 1), and the NRC staffs model safety evaluation (SE) (Reference 4) as part of the CLIIP. TVA has concluded that the information in TR NEDC-32988, TSTF-423-A, and the NRC staffs model SE are applicable to Browns Ferry Nuclear Plant (BFN) and justify this license amendment request (LAR) for the incorporation of the changes to the BFN TS.

2.2 Optional Changes and Variations TVA is proposing variations or deviations from TR NEDC-32988-A, the TS changes described in the TSTF-423-A, Revision 1, or the NRC staffs model SE referenced in the Federal Register on February 18, 2011 (76 FR 9614) as part of the CLIIP Notice of Availability. The variations described in Table 1 are considered to be non-technical in nature.

Additionally, TVA is committing to the guidance in Section 11 of NUMARC 93-01 without specifically committing to Revision 3 as referenced in the NRC staffs model SE. This is because TVA is already following the guidance of NUMARC 93-01, Revision 4F, which was endorsed by the NRC in Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4, August 2018.

CNL-25-041 E1 - 3 of 11 Table 1: TSTF-423 vs. BFN Cross-Reference TSTF-423-A TS Section Title / Section / Condition Description TSTF-423-A TS/RA BFN TS/RA Disposition Comments Reactor Protection System (RPS) Electric Power Monitoring 3.3.8.2 3.3.8.2 C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or 3 C.1 C.2 C.1 C.2 Added LCO 3.0.4.a Note Deleted C.2 No variation No variation Safety/Relief Valves (S/RVs) 3.4.3 3.4.3 B. [Required Action and associated Completion Time of Condition A not met.]

B.1 B.2 N/A N/A No change No change BFN does not have this RA BFN does not have this RA C. [Three] or more [required]

S/RVs inoperable.

C.1 C.2 A.1 A.2 No change No change Different STS lettering from BFN Different STS lettering from BFN ECCS - Operating 3.5.1 3.5.1 B. Required Action and associated Completion Time of Condition A not met.

B.1 B.2 B.1 B.2 Added LCO 3.0.4.a Note Deleted B.2 No variation No variation G. [New] Required Action and associated Completion Time of Condition C, D, E, or F not met.

G.1 [New]

Added Condition G, RA G.1, and Completion Time No variation H. [Re-lettered] Two or more ADS valves inoperable H.1 [Re-lettered]

H.2 [Re-lettered]

H.1 [Re-lettered]

H.2 [Re-lettered]

Re-lettered only Re-lettered only No variation No variation I. [Re-lettered] Two or more low pressure ECCS injection/spray subsystems inoperable for reasons other than Condition A.

OR HPCI System and one or more ADS valves inoperable.

I.1 [Re-lettered]

Re-lettered only No variation CNL-25-041 E1 - 4 of 11 TSTF-423-A TS Section Title / Section / Condition Description TSTF-423-A TS/RA BFN TS/RA Disposition Comments RCIC System 3.5.3 3.5.3 B. Required Action and associated Completion Time not met.

B.1 B.2 B.1 B.2 Added LCO 3.0.4.a Note Deleted B.2 No variation No variation Low-Low Set (LLS) Valves 3.6.1.6 N/A N/A BFN TS does not include a specification for LLS valves.

Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.7 3.6.1.5 D. [New] Required Action and associated Completion Time of Condition C not met.

D.1 [New]

Added Condition D, RA D.1, and Completion Time No variation E. [Re-lettered] Two [or more] lines with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening.

E.1 [Re-lettered]

Re-lettered only No variation F. [Re-lettered] Required Action and associated Completion Time of Condition A, B, or E not met.

F.1 [Re-lettered]

F.2 [Re-lettered]

F.1 [Re-lettered]

F.2 [Re-lettered]

Re-lettered only Re-lettered only No variation No variation Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.8 3.6.1.6 B. [New] Required Action and associated Completion Time of Condition A not met.

B.1 [New]

Added Condition B, RA B.1, and Completion Time No variation C. [Re-lettered] One suppression chamber-to-drywell vacuum breaker not closed.

C.1 [Re-lettered]

Re-lettered only No variation D. [Re-lettered] Required Action and associated Completion Time of Condition C not met.

D.1 [Re-lettered]

D.2 [Re-lettered]

D.1 [Re-lettered]

D.2 [Re-lettered]

Re-lettered only Re-lettered only No variation No variation CNL-25-041 E1 - 5 of 11 TSTF-423-A TS Section Title / Section / Condition Description TSTF-423-A TS/RA BFN TS/RA Disposition Comments Main Steam Isolation Valve (MSIV) Leakage Control System (LCS) 3.6.1.9 N/A N/A BFN TS does not include a specification for MSIV LCS.

Residual Heat Removal (RHR) Suppression Pool Cooling 3.6.2.3 3.6.2.3 B. [New] Required Action and associated Completion Time of Condition A not met.

B.1 [New]

C.1 [New]

Added Condition C, RA C.1, and Completion Time.

Added Condition A or B to scope of Condition C.

Different STS lettering from BFN C. [Re-lettered] Two RHR suppression pool cooling subsystems inoperable.

C.1 [Re-lettered]

D.1 [Re-lettered]

Re-lettered and replaced required in RA D.1 with two to match STS style.

Comparable condition for BFN is for three or more subsystems inoperable, but intent is the same.

D. [Re-lettered] Required Action and associated Completion Time of Condition C not met.

D.1 [Re-lettered]

D.2 [Re-lettered]

E.1 [Re-lettered]

E.2 [Re-lettered]

Re-lettered Re-lettered Added Condition D to scope of Condition E.

Different STS lettering from BFN Different STS lettering from BFN Residual Heat Removal (RHR) Suppression Pool Spray 3.6.2.4 3.6.2.4 C. Required Action and associated Completion Time not met.

C.1 C.2 D.1 D.2 Added LCO 3.0.4.a Note Deleted D.2 Different STS lettering from BFN Secondary Containment 3.6.4.1 3.6.4.1 B. Required Action and associated Completion Time of Condition A not met.

B.1 B.2 B.1 B.2 Added LCO 3.0.4.a Note Deleted B.2 No variation Standby Gas Treatment (SGT) System 3.6.4.3 3.6.4.3 B. Required Action and associated Completion Time of Condition A not met in MODE 1, 2, or 3.

B.1 B.2 B.1 B.2 Added LCO 3.0.4.a Note Deleted B.2 No variation CNL-25-041 E1 - 6 of 11 TSTF-423-A TS Section Title / Section / Condition Description TSTF-423-A TS/RA BFN TS/RA Disposition Comments D. Two SGT subsystems inoperable in MODE 1, 2, or

3.

D.1 C.1 Replaced LCO 3.0.3 entry with MODE 3 entry for RA C.1 and replaced Immediately with 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Completion Time.

Wording and lettering of Condition is different between BFN and STS, but intent is the same.

Residual Heat Removal Service Water (RHRSW)

System 3.7.1 3.7.1 D. [New] Required Action and associated Completion Time of Condition A, B, or C not met.

D.1 [New]

E.1 [New]

Added Condition E, RA E.1, and Completion Time Different STS lettering from BFN E. [Re-lettered] Both RHRSW subsystems inoperable for reasons other than Condition B.

E.1 [Re-lettered]

G.1 [Re-lettered]

Re-lettered only Wording and lettering of Condition is different between BFN and STS, but intent is the same.

F. [Re-lettered] Required Action and associated Completion Time of Condition E not met.

F.1 [Re-lettered]

F.2 [Re-lettered]

H.1 [Re-lettered]

H.2 [Re-lettered]

Re-lettered Re-lettered Added Condition F or G to scope of Condition H.

Different STS lettering from BFN Different STS lettering from BFN

[Plant Service Water (PSW)]

System and [Ultimate Heat Sink (UHS)]

3.7.2 3.7.2 C. [New] Required Action and associated Completion Time of Condition A or B not met.

C.1 [New]

B.1 B.2 Added LCO 3.0.4.a Note Deleted B.2 Kept Condition A as scope of Condition B.

Separated BFN Condition B to create new Condition C similar to STS Condition G. Wording and lettering of Condition is different between BFN and STS, but intent is the same.

D. [Re-lettered] [One or more cooling towers with one cooling tower fan inoperable.]

D.1 [Re-lettered]

N/A No change BFN does not have this RA E. [Re-lettered] [Water temperature of the UHS >

[90]°F and [ ]°F.]

E.1 [Re-lettered]

N/A No change BFN does not have this RA CNL-25-041 E1 - 7 of 11 TSTF-423-A TS Section Title / Section / Condition Description TSTF-423-A TS/RA BFN TS/RA Disposition Comments F. [Re-lettered] One [PSW]

subsystem inoperable for reasons other than Condition[s] A [and D].

F.1 [Re-lettered]

N/A No change BFN does not have this RA G. [Re-lettered] [Required Action and associated Completion Time of Condition E not met.]

OR Both [PSW] subsystems inoperable for reasons other than Condition[s] B [and D].

[OR

[UHS] inoperable for reasons other than Condition D [or E].]

G.1 [Re-lettered]

G.2 [Re-lettered]

C.1 [New]

C.2 [New]

Added Condition C, RA C.1 and C.2, and Completion Times Deleted Condition E from scope of Condition C.

BFN does not have Condition E, so scope of new Condition C is the remaining two Conditions regarding EECW pump inoperability or UHS inoperability.

[Main Control Room Environmental Control (MCREC)] System 3.7.4 3.7.3 C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or 3.

C.1 C.2 E.1 E.2 Added LCO 3.0.4.a Note Deleted E.2 Added Condition A, B, C, or D to scope of Condition E.

Different STS lettering from BFN Different STS lettering from BFN E. Two [MCREC]

subsystems inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

E.1 F.1 Replaced LCO 3.0.3 entry with MODE 3 entry for RA F.1, and replaced Immediately with 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Completion Time.

Wording and lettering of Condition is different between BFN and STS, but intent is the same.

[Control Room Air Conditioning (AC)] System 3.7.5 3.7.4 CNL-25-041 E1 - 8 of 11 TSTF-423-A TS Section Title / Section / Condition Description TSTF-423-A TS/RA BFN TS/RA Disposition Comments B. Required Action and associated Completion Time of Condition A not met in MODE 1, 2, or 3.

B.1 B.2 C.1 C.2 Added LCO 3.0.4.a Note Deleted C.2 Added Condition A or B to scope of Condition C.

Different STS lettering from BFN Different STS lettering from BFN D. Two [control room AC]

subsystems inoperable in MODE 1, 2, or 3.

D.1 N/A No change BFN does not have this RA Main Condenser Offgas 3.7.6 N/A N/A BFN TS does not include a specification for main condenser offgas.

AC Sources - Operating 3.8.1 3.8.1 G. Required Action and associated Completion Time of Condition A, B, C, D, E, or

[F] not met.

G.1 G.2 I.1 I.2 Added LCO 3.0.4.a Note Deleted I.2 Added Condition A, B, C, D, E, F, or H to scope of Condition I.

Different STS lettering from BFN Different STS lettering from BFN DC Sources - Operating 3.8.4 3.8.4 D. Required Action and associated Completion Time of Condition A[, B, or C] not met for station service DC subsystem.

D.1 D.2 B.1 B.2 Added LCO 3.0.4.a Note Deleted B.2 Different STS lettering from BFN Different STS lettering from BFN Inverters - Operating 3.8.7 N/A N/A BFN TS does not include a specification for inverters during operation.

Distribution Systems -

Operating 3.8.9 3.8.7 D. Required Action and associated Completion Time of Condition A, B, or C not met.

D.1 D.2 G.1 (Unit 1) /

H.1 (Unit 2/3)

G.2 (Unit 1) /

H.2 (Unit 2/3)

Added LCO 3.0.4.a Note Deleted B.2 Added Condition A, B, C, D, E, or I to scope of Condition G.

Different STS lettering from BFN Different STS lettering from BFN CNL-25-041 E1 - 9 of 11

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Tennessee Valley Authority (TVA) has evaluated the proposed changes to the technical specifications (TS) using the criteria in Title 10 of the Code of Federal Regulations (10 CFR) 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

Description of Amendment Request: A change is proposed to the TS of Browns Ferry Nuclear Plant (BFN), consistent with Technical Specifications Task Force (TSTF)-423-A, Revision 1, to allow, for some systems, entry into hot shutdown rather than cold shutdown to repair equipment, if risk is assessed and managed consistent with the program in place for complying with the requirements of 10 CFR 50.65(a)(4). Changes proposed in TSTF-423-A will be made to the BFN TS for selected Required Action end states.

Basis for no significant hazards consideration determination: As required by 10 CFR 50.91(a),

TVA analysis of the issue of no significant hazards consideration is presented below.

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change allows a change to certain required end states when the TS Completion Times for remaining in power operation will be exceeded. Most of the requested TS changes are to permit an end state of hot shutdown (Mode 3) rather than an end state of cold shutdown (Mode 4) contained in the current TS. The request was limited to: (1) those end states where entry into the shutdown mode is for a short interval, (2) entry is initiated by inoperability of a single train of equipment or a restriction on a plant operational parameter, unless otherwise stated in the applicable TS, and (3) the primary purpose is to correct the initiating condition and return to power operation as soon as is practical. Risk insights from both the qualitative and quantitative risk assessments were used in specific TS assessments.

Such assessments are documented in Section 6 of topical report NEDC-32988-A, Revision 2, Technical Justification to Support Risk Informed Modification to Selected Required Action End States for BWR Plants. They provide an integrated discussion of deterministic and probabilistic issues, focusing on specific TSs, which are used to support the proposed TS end state and associated restrictions. The Nuclear Regulatory Commission staff finds that the risk insights support the conclusions of the specific TS assessments. Therefore, the probability of an accident previously evaluated is not significantly increased, if at all. The consequences of an accident after adopting TSTF-423-A are no different than the consequences of an accident prior to adopting TSTF-423-A. Therefore, the consequences of an accident previously evaluated are not significantly affected by this change. The addition of a requirement to assess and manage the risk introduced by this change will further minimize possible concerns.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

CNL-25-041 E1 - 10 of 11

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed). If risk is assessed and managed, allowing a change to certain required end states when the TS Completion Times for remaining in power operation are exceeded (i.e., entry into hot shutdown rather than cold shutdown to repair equipment) will not introduce new failure modes or effects and will not, in the absence of other unrelated failures, lead to an accident whose consequences exceed the consequences of accidents previously evaluated. The addition of a requirement to assess and manage the risk introduced by this change and the commitment by the licensee to adhere to the guidance in TSTF-IG-05-02, Implementation Guidance for TSTF-423, Revision 1, Technical Specifications End States, NEDC-32988-A, will further minimize possible concerns.

Thus, based on the above, this change does not create the possibility of a new or different kind of accident from an accident previously evaluated.

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

Response: No The proposed change allows, for some systems, entry into hot shutdown rather than cold shutdown to repair equipment, if risk is assessed and managed. The Boiling Water Reactor Owners Groups risk assessment approach is comprehensive and follows NRC staff guidance as documented in Regulatory Guides (RG) 1.174 and 1.177. In addition, the analyses show that the criteria of the three-tiered approach for allowing TS changes are met. The risk impact of the proposed TS changes was assessed following the three-tiered approach recommended in RG 1.177. A risk assessment was performed to justify the proposed TS changes. The net change to the margin of safety is insignificant.

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

Based upon the reasoning presented above, TVA concludes that the requested change involves no significant hazards consideration, as set forth in 10 CFR 50.92(c), Issuance of Amendment.

3.2 Verifications, Commitments, and Additional Information Needed TVA commits to the regulatory commitments in Enclosure 2. In addition, TVA has proposed TS Bases consistent with TSTF-423-A, Revision 1, which provide guidance and details on how to implement the new requirements. Implementation of TSTF-423-A requires that risk be managed and assessed, and the licensees configuration risk management program is adequate to satisfy this requirement. The risk assessment need not be quantified but may be a qualitative assessment of the vulnerability of systems and components when one or more systems are not able to perform their associated function. Finally, TVA has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications (STS).

CNL-25-041 E1 - 11 of 11 4.0 ENVIRONMENTAL EVALUATION The proposed change would revise a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

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

5.0 REFERENCES

1. TSTF-423, Revision 1, Technical Specifications End States, NEDC-32988-A, dated December 22, 2009 (ADAMS Accession No. ML093570241).

2. Federal Register, Vol. 76, No. 34, p. 9614, Notice of Availability of the Proposed Models for Plant-Specific Adoption of Technical Specifications Task Force (TSTF)

Traveler TSTF-423, Revision 1, Technical Specifications End States, NEDC-32988-A, for Boiling Water Reactor Plants Using the Consolidated Line Item Improvement Process, dated February 18, 2011 (ADAMS Accession No. ML102730585).

3. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required Action End States for BWR Plants, December 2002 (ADAMS Package Accession No. ML030170060).

4. NRC Model Safety Evaluation of TSTF-423, Revision 1, dated February 2, 2011 (ADAMS Accession No. ML102730688).

CNL-25-041.1 Proposed Technical Specification Changes (Markups) for BFN Unit 1 (18 pages)

RPS Electric Power Monitoring 3.3.8.2 BFN-UNIT 1 3.3-75 Amendment No. 234 3.3 INSTRUMENTATION 3.3.8.2 Reactor Protection System (RPS) Electric Power Monitoring LCO 3.3.8.2 Two RPS electric power monitoring assemblies shall be OPERABLE for each inservice RPS motor generator set or alternate power supply.

APPLICABILITY:

MODES 1, 2, and 3, MODES 4 and 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or both inservice power supplies with one electric power monitoring assembly inoperable.

A.1 Remove associated inservice power supply(s) from service.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. One or both inservice power supplies with both electric power monitoring assemblies inoperable.

B.1 Remove associated inservice power supply(s) from service.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or

3.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

ECCS - Operating 3.5.1 BFN-UNIT 1 3.5-1 Amendment No. 234, 240, 249, 311, 328 May 2, 2023 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 injection/spray subsystem inoperable.

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

A.1 Restore low pressure ECCS injection/spray subsystem(s) to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

ECCS - Operating 3.5.1 BFN-UNIT 1 3.5-3 Amendment No. 234, 240 March 12, 2001 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. Two or more ADS valves inoperable.

OR Required Action and associated Completion Time of Condition C, D, E, or F not met.

G.1 Be in MODE 3.

AND G.2 Reduce reactor steam dome pressure to 150 psig.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours H. Two or more low pressure ECCS injection/spray subsystems inoperable for reasons other than Condition A.

OR HPCI System and one or more ADS valves inoperable.

H.1 Enter LCO 3.0.3.

Immediately H

H H

G. Required Action and associated Completion Time of Condition C, D, E, or F not met G.1 ------------ NOTE ------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

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

I

RCIC System 3.5.3 BFN-UNIT 1 3.5-12 Amendment No. 234, 249, 311, 328 May 2, 2023 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 means High Pressure Coolant Injection System is OPERABLE.

Immediately AND A.2 Restore RCIC System to OPERABLE status.

14 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Reduce reactor steam dome pressure to 150 psig.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.5 BFN-UNIT 1 3.6-20 Amendment No. 234 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One line with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening.

C.1 Restore the vacuum breaker(s) to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months D. Two lines with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening.

D.1 Restore all vacuum breakers in one line to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months E. Required Action and Associated Completion Time not met.

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours D. Required Action and associated Completion Time of Condition C not met.

D.1 ------------ NOTE ------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

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

E F

F F

of Condition A, B, or E

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 BFN-UNIT 1 3.6-22 Amendment No. 234 3.6 CONTAINMENT SYSTEMS 3.6.1.6 Suppression Chamber-to-Drywell Vacuum Breakers LCO 3.6.1.6 Ten suppression chamber-to-drywell vacuum breakers shall be OPERABLE for opening.

AND Twelve suppression chamber-to-drywell vacuum breakers shall be closed, except when performing their intended function.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required suppression chamber-to-drywell vacuum breaker inoperable for opening.

A.1 Restore one vacuum breaker to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. One suppression chamber-to-drywell vacuum breaker not closed.

B.1 Close the open vacuum breaker.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months C. Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours of Condition C C

C D

D D

B. Required Action and associated Completion Time of Condition A not met.

B.1 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

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

RHR Suppression Pool Cooling 3.6.2.3 BFN-UNIT 1 3.6-31 Amendment No. 234, 241, 328 May 2, 2023 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Four RHR suppression pool cooling subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression pool cooling subsystem inoperable.

A.1 Restore the RHR suppression pool cooling subsystem to OPERABLE status.

30 days B. Two RHR suppression pool cooling subsystems inoperable.

B.1 Restore one RHR suppression pool cooling subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program C. Three or more RHR suppression pool cooling subsystems inoperable.

C.1 Restore required RHR suppression pool cooling subsystems to OPERABLE status.

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

C. Required Action and associated Completion Time of Condition A or B not met.

C.1 ------------ NOTE ------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

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

D two

RHR Suppression Pool Cooling 3.6.2.3 BFN-UNIT 1 3.6-32 Amendment No. 234 241 June 8, 2001 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and associated Completion Time not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours E

E E

of Condition D

RHR Suppression Pool Spray 3.6.2.4 BFN-UNIT 1 3.6-34 Amendment No. 234, 328 May 2, 2023 3.6 CONTAINMENT SYSTEMS 3.6.2.4 Residual Heat Removal (RHR) Suppression Pool Spray LCO 3.6.2.4 Four RHR suppression pool spray subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression pool spray subsystem inoperable.

A.1 Restore the RHR suppression pool spray subsystem to OPERABLE status.

30 days B. Two RHR suppression pool spray subsystems inoperable.

B.1 Restore one RHR suppression pool spray subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Program C. Three or more RHR suppression pool spray subsystems inoperable.

C.1 Restore required RHR suppression pool spray subsystems to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months D. Required Action and associated Completion Time not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Secondary Containment 3.6.4.1 BFN-UNIT 1 3.6-44 Amendment No. 234, 251, 311 December 26, 2019 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 inoperable.

A.1 Restore secondary containment to OPERABLE status.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

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

LCO 3.0.4.a is not applicable when entering MODE 3.

SGT System 3.6.4.3 BFN-UNIT 1 3.6-51 Amendment No. 234, 251, 311 December 26, 2019 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 inoperable.

A.1 Restore SGT subsystem to OPERABLE status.

7 days B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours C. Two or three SGT subsystems inoperable.

C.1 Enter LCO 3.0.3.

Immediately

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

LCO 3.0.4.a is not applicable when entering MODE 3.

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

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

RHRSW System 3.7.1 BFN-UNIT 1 3.7-4 Amendment No. 234 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Three or more required RHRSW pumps inoperable.

E.1 Restore one RHRSW pump to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months F. Three or more RHRSW subsystems inoperable.

F.1

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

Enter applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by the RHRSW System.

Restore one RHRSW subsystem to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months G. Required Action and associated Completion Time not met.

G.1 Be in MODE 3.

AND G.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours F

F G

G H

H H

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

E.1 ------------ NOTE ------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

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

EECW System and UHS 3.7.2 BFN-UNIT 1 3.7-6 Amendment No. 234, 328 3.7 PLANT SYSTEMS 3.7.2 Emergency Equipment Cooling Water (EECW) System and Ultimate Heat Sink (UHS)

LCO 3.7.2 The EECW System with three pumps and UHS shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required EECW pump inoperable.

A.1 Restore the required EECW pump to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Program B. Required Action and associated Completion Time of Condition A not met.

OR Two or more required EECW pumps inoperable.

OR UHS inoperable.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours C.

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

LCO 3.0.4.a is not applicable when entering MODE 3.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

CREV System 3.7.3 BFN-UNIT 1 3.7-9 Amendment 234, 246, 251, 275, 282, 311 December 26, 2019 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two CREV subsystems inoperable due to inoperable High 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).

C.1 Restore HEPA filter and one charcoal adsorber to OPERABLE status.

7 days D. One CREV subsystem inoperable due to inoperable charcoal adsorber which does not impact the ability of CREV subsystem to meet flowrate requirements specified in the VFTP.

D.1 Restore charcoal adsorber to OPERABLE status.

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

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours F. Two CREV subsystems inoperable for reasons other than Condition B or C.

F.1 Enter LCO 3.0.3.

Immediately

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

LCO 3.0.4.a is not applicable when entering MODE 3.

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

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

Control Room AC System 3.7.4 BFN-UNIT 1 3.7-13 Amendment No. 234 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Two Unit 1 and 2 control room AC subsystems inoperable.

B.1 Initiate action to restore one Unit 1 and 2 control room AC subsystem to OPERABLE status.

Immediately AND B.2 Place an alternate method of cooling in operation.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND B.3 Restore one control room AC subsystem to OPERABLE status.

7 days C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or 3.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

AC Sources - Operating 3.8.1 BFN-UNIT 1 3.8-6 Amendment No. 234 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. Two or more Unit 1 and 2 DGs inoperable.

H.1 Restore all but one Unit 1 and 2 DG to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months I.

Required Action and Associated Completion Time of Condition A, B, C, D, E, F, or H not met.

I.1 Be in MODE 3.

AND I.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours J. One or more required offsite circuits and two or more Unit 1 and 2 DGs inoperable.

OR Two required offsite circuits and one or more Unit 1 and 2 DGs inoperable.

OR Two divisions of 480 V load shed logic inoperable.

OR Two divisions of common accident signal logic inoperable.

J.1 Enter LCO 3.0.3.

Immediately (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

DC Sources - Operating 3.8.4 BFN-UNIT 1 3.8-23 Amendment No. 234 ACTIONS (continued)

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

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours C. One or more DG DC electrical power subsystem(s) inoperable.

C.1 Declare associated DG inoperable.

Immediately D. Unit 3 3EB Shutdown Board DC electrical power subsystem inoperable.

D.1 Declare the affected CREV subsystem inoperable.

Immediately

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Distribution Systems - Operating 3.8.7 BFN-UNIT 1 3.8-37 Amendment No. 234, 254, 323, 328 May 2, 2023 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Unit 1 and 2 4.16 kV Shutdown Board A and B inoperable, for reasons other than Condition I.

OR Unit 1 and 2 4.16 kV Shutdown Board C and D inoperable, for reasons other than Condition I.

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

Enter applicable conditions and required actions of Condition B, C, and F when Condition E results in no power source to a required 480 volt board.

E.1 Restore one 4.16 kV Shutdown Board to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OR In accordance with the Risk Informed Completion Time Program F. One or more required Unit 2 or 3 AC or DC Boards inoperable, for reasons other than Condition I.

F.1 Declare the affected SGT or CREV subsystem inoperable.

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

G.1 Be in MODE 3.

AND G.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

CNL-25-041.2 Proposed Technical Specification Changes (Markups) for BFN Unit 2 (18 pages)

RPS Electric Power Monitoring 3.3.8.2 BFN-UNIT 2 3.3-76 Amendment No. 253 3.3 INSTRUMENTATION 3.3.8.2 Reactor Protection System (RPS) Electric Power Monitoring LCO 3.3.8.2 Two RPS electric power monitoring assemblies shall be OPERABLE for each inservice RPS motor generator set or alternate power supply.

APPLICABILITY:

MODES 1, 2, and 3, MODES 4 and 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or both inservice power supplies with one electric power monitoring assembly inoperable.

A.1 Remove associated inservice power supply(s) from service.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B.

One or both inservice power supplies with both electric power monitoring assemblies inoperable.

B.1 Remove associated inservice power supply(s) from service.

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

Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or

3.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

ECCS - Operating 3.5.1 BFN-UNIT 2 3.5-1 Amendment No. 253, 269, 286, 294, 334, 351 May 2, 2023 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 injection/spray subsystem inoperable.

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

A.1 Restore low pressure ECCS injection/spray subsystem(s) to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

ECCS - Operating 3.5.1 BFN-UNIT 2 3.5-3 Amendment No. 253, 269 March 12, 2001 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. Two or more ADS valves inoperable.

OR Required Action and associated Completion Time of Condition C, D, E, or F not met.

G.1 Be in MODE 3.

AND G.2 Reduce reactor steam dome pressure to 150 psig.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours H. Two or more low pressure ECCS injection/spray subsystems inoperable for reasons other than Condition A.

OR HPCI System and one or more ADS valves inoperable.

H.1 Enter LCO 3.0.3.

Immediately H

H H

I I

G. Required Action and associated Completion Time of Condition C, D, E, or F not met G.1 ------------ NOTE ------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

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

RCIC System 3.5.3 BFN-UNIT 2 3.5-12 Amendment No. 253, 286, 334, 351 May 2, 2023 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System 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 means High Pressure Coolant Injection System is OPERABLE.

Immediately AND A.2 Restore RCIC System to OPERABLE status.

14 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Reduce reactor steam dome pressure to 150 psig.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours LCO 3.5.3

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.5 BFN-UNIT 2 3.6-20 Amendment No. 253 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One line with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening.

C.1 Restore the vacuum breaker(s) to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months D. Two lines with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening.

D.1 Restore all vacuum breakers in one line to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months E. Required Action and Associated Completion Time not met.

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours E

E F

F F

D. Required Action and associated Completion Time of Condition C not met.

D.1 ------------ NOTE ------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of Condition A, B, or E

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 BFN-UNIT 2 3.6-22 Amendment No. 253 3.6 CONTAINMENT SYSTEMS 3.6.1.6 Suppression Chamber-to-Drywell Vacuum Breakers LCO 3.6.1.6 Ten suppression chamber-to-drywell vacuum breakers shall be OPERABLE for opening.

AND Twelve suppression chamber-to-drywell vacuum breakers shall be closed, except when performing their intended function.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required suppression chamber-to-drywell vacuum breaker inoperable for opening.

A.1 Restore one vacuum breaker to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. One suppression chamber-to-drywell vacuum breaker not closed.

B.1 Close the open vacuum breaker.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months C. Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours C

C D

D D

B. Required Action and associated Completion Time of Condition A not met.

B.1 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

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

RHR Suppression Pool Cooling 3.6.2.3 BFN-UNIT 2 3.6-31 Amendment No. 253, 272, 351 May 2, 2023 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Four RHR suppression pool cooling subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression pool cooling subsystem inoperable.

A.1 Restore the RHR suppression pool cooling subsystem to OPERABLE status.

30 days B. Two RHR suppression pool cooling subsystems inoperable.

B.1 Restore one RHR suppression pool cooling subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program C. Three or more RHR suppression pool cooling subsystems inoperable.

C.1 Restore required RHR suppression pool cooling subsystems to OPERABLE status.

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

D D

C. Required Action and associated Completion Time of Condition A or B not met.

C.1 ------------ NOTE ------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

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

RHR Suppression Pool Cooling 3.6.2.3 BFN-UNIT 2 3.6-32 Amendment No. 253 272 June 8, 2001 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and associated Completion Time not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours E

E E

of Condition C or D

RHR Suppression Pool Spray 3.6.2.4 BFN-UNIT 2 3.6-34 Amendment No. 253, 351 May 2, 2023 3.6 CONTAINMENT SYSTEMS 3.6.2.4 Residual Heat Removal (RHR) Suppression Pool Spray LCO 3.6.2.4 Four RHR suppression pool spray subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression pool spray subsystem inoperable.

A.1 Restore the RHR suppression pool spray subsystem to OPERABLE status.

30 days B. Two RHR suppression pool spray subsystems inoperable.

B.1 Restore one RHR suppression pool spray subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program C. Three or more RHR suppression pool spray subsystems inoperable.

C.1 Restore required RHR suppression pool spray subsystems to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months D. Required Action and associated Completion Time not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Secondary Containment 3.6.4.1 BFN-UNIT 2 3.6-44 Amendment No. 253, 290, 334 December 26, 2019 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 inoperable.

A.1 Restore secondary containment to OPERABLE status.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

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

LCO 3.0.4.a is not applicable when entering MODE 3.

SGT System 3.6.4.3 BFN-UNIT 2 3.6-51 Amendment No. 253, 290, 334 December 26, 2019 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 inoperable.

A.1 Restore SGT subsystem to OPERABLE status.

7 days B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours C. Two or three SGT subsystems inoperable.

C.1 Enter LCO 3.0.3.

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

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

LCO 3.0.4.a is not applicable when entering MODE 3.

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

RHRSW System 3.7.1 BFN-UNIT 2 3.7-4 Amendment No. 254, 323 August 14, 2017 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Three or more required RHRSW pumps inoperable.

E.1 Restore one RHRSW pump to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months F. Three or more RHRSW subsystems inoperable.

F.1

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

Enter applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by the RHRSW System.

Restore one RHRSW subsystem to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months G. Required Action and associated Completion Time not met.

G.1 Be in MODE 3.

AND G.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours F

F G

G H

H H

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

E.1 ------------ NOTE ------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of Condition F or G

EECW System and UHS 3.7.2 BFN-UNIT 2 3.7-7 Amendment No. 254, 351 May 2, 2023 3.7 PLANT SYSTEMS 3.7.2 Emergency Equipment Cooling Water (EECW) System and Ultimate Heat Sink (UHS)

LCO 3.7.2 The EECW System with three pumps and UHS shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required EECW pump inoperable.

A.1 Restore the required EECW pump to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

OR Two or more required EECW pumps inoperable.

OR UHS inoperable.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours C.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

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

LCO 3.0.4.a is not applicable when entering MODE 3.

CREV System 3.7.3 BFN-UNIT 2 3.7-10 Amendment 254, 283, 290, 302, 308, 334 December 26, 2019 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two CREV subsystems inoperable due to inoperable High 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).

C.1 Restore HEPA filter and one charcoal adsorber to OPERABLE status.

7 days D. One CREV subsystem inoperable due to inoperable charcoal adsorber which does not impact the ability of CREV subsystem to meet flowrate requirements specified in the VFTP.

D.1 Restore charcoal adsorber to OPERABLE status.

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

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours F. Two CREV subsystems inoperable for reasons other than Condition B or C.

F.1 Enter LCO 3.0.3.

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

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

LCO 3.0.4.a is not applicable when entering MODE 3.

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

Control Room AC System 3.7.4 BFN-UNIT 2 3.7-14 Amendment No. 254 September 08, 1998 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Two Unit 1 and 2 control room AC subsystems inoperable.

B.1 Initiate action to restore one Unit 1 and 2 control room AC subsystem to OPERABLE status.

Immediately AND B.2 Place an alternate method of cooling in operation.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND B.3 Restore one control room AC subsystem to OPERABLE status.

7 days C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or

3.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

AC Sources - Operating 3.8.1 BFN-UNIT 2 3.8-6 Amendment No. 253 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. Two or more Unit 1 and 2 DGs inoperable.

H.1 Restore all but one Unit 1 and 2 DG to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months I.

Required Action and Associated Completion Time of Condition A, B, C, D, E, F, or H not met.

I.1 Be in MODE 3.

AND I.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours J. One or more required offsite circuits and two or more Unit 1 and 2 DGs inoperable.

OR Two required offsite circuits and one or more Unit 1 and 2 DGs inoperable.

OR Two divisions of 480 V load shed logic inoperable.

OR Two divisions of common accident signal logic inoperable.

J.1 Enter LCO 3.0.3.

Immediately (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

DC Sources - Operating 3.8.4 BFN-UNIT 2 3.8-23 Amendment No. 253 ACTIONS (continued)

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

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours C. One or more DG DC electrical power subsystem(s) inoperable.

C.1 Declare associated DG inoperable.

Immediately D. Unit 3 3EB Shutdown Board DC electrical power subsystem inoperable.

D.1 Declare the affected CREV subsystem inoperable.

Immediately

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Distribution Systems - Operating 3.8.7 BFN-UNIT 2 3.8-37 Amendment No. 253, 346, 351 May 2, 2023 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Unit 1 and 2 4.16 kV Shutdown Board A and B inoperable, for reasons other than Condition J.

OR Unit 1 and 2 4.16 kV Shutdown Board C and D inoperable, for reasons other than Condition J.

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

Enter applicable conditions and required actions of Condition B, C, D, and G when Condition F results in no power source to a required 480 volt board.

F.1 Restore one 4.16 kV Shutdown Board to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OR In accordance with the Risk Informed Completion Time Program G. One or more required Unit 1 or 3 AC or DC Boards inoperable, for reasons other than Condition J.

G.1 Declare the affected SGT or CREV subsystem inoperable.

Immediately H. Required Action and associated Completion Time of Condition A, B, D, E, F, or J not met.

H.1 Be in MODE 3.

AND H.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours I.

Two or more electrical power distribution subsystems inoperable that result in a loss of function, for reasons other than Condition J.

I.1 Enter LCO 3.0.3.

Immediately (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

CNL-25-041.3 Proposed Technical Specification Changes (Markups) for BFN Unit 3 (18 pages)

RPS Electric Power Monitoring 3.3.8.2 BFN-UNIT 3 3.3-76 Amendment No. 213 September 03, 1998 3.3 INSTRUMENTATION 3.3.8.2 Reactor Protection System (RPS) Electric Power Monitoring LCO 3.3.8.2 Two RPS electric power monitoring assemblies shall be OPERABLE for each inservice RPS motor generator set or alternate power supply.

APPLICABILITY:

MODES 1, 2, and 3, MODES 4 and 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or both inservice power supplies with one electric power monitoring assembly inoperable.

A.1 Remove associated inservice power supply(s) from service.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. One or both inservice power supplies with both electric power monitoring assemblies inoperable.

B.1 Remove associated inservice power supply(s) from service.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or

3.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

ECCS - Operating 3.5.1 BFN-UNIT 3 3.5-1 Amendment No. 212, 229, 244, 294, 311 May 2, 2023 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 injection/spray subsystem inoperable.

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

A.1 Restore low pressure ECCS injection/spray subsystem(s) to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Program B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

ECCS - Operating 3.5.1 BFN-UNIT 3 3.5-3 Amendment No. 212, 229 March 12, 2001 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. Two or more ADS valves inoperable.

OR Required Action and associated Completion Time of Condition C, D, E, or F not met.

G.1 Be in MODE 3.

AND G.2 Reduce reactor steam dome pressure to 150 psig.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours H. Two or more low pressure ECCS injection/spray subsystems inoperable for reasons other than Condition A.

OR HPCI System and one or more ADS valves inoperable.

H.1 Enter LCO 3.0.3.

Immediately H

H H

I I

G. Required Action and associated Completion Time of Condition C, D, E, or F not met G.1 ------------ NOTE ------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

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

RCIC System 3.5.3 BFN-UNIT 3 3.5-12 Amendment No. 212, 244, 294, 311 May 2, 2023 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 means High Pressure Coolant Injection System is OPERABLE.

Immediately AND A.2 Restore RCIC System to OPERABLE status.

14 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Reduce reactor steam dome pressure to 150 psig.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.5 BFN-UNIT 3 3.6-20 Amendment No. 212 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One line with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening.

C.1 Restore the vacuum breaker(s) to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months D. Two lines with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening.

D.1 Restore all vacuum breakers in one line to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months E. Required Action and Associated Completion Time not met.

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours E

E F

F F

D. Required Action and associated Completion Time of Condition C not met.

D.1 ------------ NOTE ------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of Condition A, B, or E

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 BFN-UNIT 3 3.6-22 Amendment No. 212 3.6 CONTAINMENT SYSTEMS 3.6.1.6 Suppression Chamber-to-Drywell Vacuum Breakers LCO 3.6.1.6 Ten suppression chamber-to-drywell vacuum breakers shall be OPERABLE for opening.

AND Twelve suppression chamber-to-drywell vacuum breakers shall be closed, except when performing their intended function.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required suppression chamber-to-drywell vacuum breaker inoperable for opening.

A.1 Restore one vacuum breaker to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. One suppression chamber-to-drywell vacuum breaker not closed.

B.1 Close the open vacuum breaker.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months C. Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours C

C D

D D

B. Required Action and associated Completion Time of Condition A not met.

B.1 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

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

RHR Suppression Pool Cooling 3.6.2.3 BFN-UNIT 3 3.6-31 Amendment No. 212, 230, 311 May 2, 2023 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Four RHR suppression pool cooling subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression pool cooling subsystem inoperable.

A.1 Restore the RHR suppression pool cooling subsystem to OPERABLE status.

30 days B. Two RHR suppression pool cooling subsystems inoperable.

B.1 Restore one RHR suppression pool cooling subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program C. Three or more RHR suppression pool cooling subsystems inoperable.

C.1 Restore required RHR suppression pool cooling subsystems to OPERABLE status.

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

D D

C. Required Action and associated Completion Time of Condition A or B not met.

C.1 ------------ NOTE ------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

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

RHR Suppression Pool Cooling 3.6.2.3 BFN-UNIT 3 3.6-32 Amendment No. 212 230 June 8, 2001 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and associated Completion Time not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours E

E E

of Condition C or D

RHR Suppression Pool Spray 3.6.2.4 BFN-UNIT 3 3.6-34 Amendment No. 212, 311 May 2, 2023 3.6 CONTAINMENT SYSTEMS 3.6.2.4 Residual Heat Removal (RHR) Suppression Pool Spray LCO 3.6.2.4 Four RHR suppression pool spray subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression pool spray subsystem inoperable.

A.1 Restore the RHR suppression pool spray subsystem to OPERABLE status.

30 days B. Two RHR suppression pool spray subsystems inoperable.

B.1 Restore one RHR suppression pool spray subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program C. Three or more RHR suppression pool spray subsystems inoperable.

C.1 Restore required RHR suppression pool spray subsystems to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months D. Required Action and associated Completion Time not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Secondary Containment 3.6.4.1 BFN-UNIT 3 3.6-44 Amendment No. 212, 249, 294 December 26, 2019 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 inoperable.

A.1 Restore secondary containment to OPERABLE status.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

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

LCO 3.0.4.a is not applicable when entering MODE 3.

SGT System 3.6.4.3 BFN-UNIT 3 3.6-51 Amendment No. 212, 249, 294 December 26, 2019 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 inoperable.

A.1 Restore SGT subsystem to OPERABLE status.

7 days B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours C. Two or three SGT subsystems inoperable.

C.1 Enter LCO 3.0.3.

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

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

LCO 3.0.4.a is not applicable when entering MODE 3.

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

RHRSW System 3.7.1 BFN-UNIT 3 3.7-4 Amendment No. 214, 283 August 14, 2017 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Three or more required RHRSW pumps inoperable.

E.1 Restore one RHRSW pump to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months F. Three or more RHRSW subsystems inoperable.

F.1

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

Enter applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by the RHRSW System.

Restore one RHRSW subsystem to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months G. Required Action and associated Completion Time not met.

G.1 Be in MODE 3.

AND G.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours F

F G

G H

H H

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

E.1 ------------ NOTE ------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of Condition F or G

EECW System and UHS 3.7.2 BFN-UNIT 3 3.7-7 Amendment No. 214, 311 May 2, 2023 3.7 PLANT SYSTEMS 3.7.2 Emergency Equipment Cooling Water (EECW) System and Ultimate Heat Sink (UHS)

LCO 3.7.2 The EECW System with three pumps and UHS shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required EECW pump inoperable.

A.1 Restore the required EECW pump to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

OR Two or more required EECW pumps inoperable.

OR UHS inoperable.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours C.

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

LCO 3.0.4.a is not applicable when entering MODE 3.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

CREV System 3.7.3 BFN-UNIT 3 3.7-10 Amendment 214, 241, 249, 261, 267, 294 December 26, 2019 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two CREV subsystems inoperable due to inoperable High 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).

C.1 Restore HEPA filter and one charcoal adsorber to OPERABLE status.

7 days D. One CREV subsystem inoperable due to inoperable charcoal adsorber which does not impact the ability of CREV subsystem to meet flowrate requirements specified in the VFTP.

D.1 Restore charcoal adsorber to OPERABLE status.

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

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours F. Two CREV subsystems inoperable for reasons other than Condition B or C.

F.1 Enter LCO 3.0.3.

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

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

LCO 3.0.4.a is not applicable when entering MODE 3.

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

Control Room AC System 3.7.4 BFN-UNIT 3 3.7-14 Amendment No. 214 September 08, 1998 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Two Unit 3 control room AC subsystems inoperable.

B.1 Initiate action to restore one Unit 3 control room AC subsystem to OPERABLE status.

Immediately AND B.2 Place an alternate method of cooling in operation.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND B.3 Restore one control room AC subsystem to OPERABLE status.

7 days C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or

3.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

AC Sources - Operating 3.8.1 BFN-UNIT 3 3.8-6 Amendment No. 212 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. Two or more Unit 3 DGs inoperable.

H.1 Restore all but one Unit 3 DG to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months I. Required Action and Associated Completion Time of Condition A, B, C, D, E, F, or H not met.

I.1 Be in MODE 3.

AND I.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours J. One or more required offsite circuits and two or more Unit 3 DGs inoperable.

OR Two required offsite circuits and one or more Unit 3 DGs inoperable.

OR Two divisions of 480 V load shed logic inoperable.

OR Two divisions of common accident signal logic inoperable.

J.1 Enter LCO 3.0.3.

Immediately (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

DC Sources - Operating 3.8.4 BFN-UNIT 3 3.8-23 Amendment No. 212 ACTIONS (continued)

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

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours C. One or more DG DC electrical power subsystem(s) inoperable.

C.1 Declare associated DG inoperable.

Immediately D. One or more Unit 1 and 2 Shutdown Board DC electrical power subsystem(s) inoperable.

D.1 Declare the affected SGT or CREV subsystem inoperable.

Immediately

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Distribution Systems - Operating 3.8.7 BFN-UNIT 3 3.8-37 Amendment No. 212, 306, 311 May 2, 2023 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Unit 3 4.16 kV Shutdown Board 3EA and 3EB inoperable.

OR Unit 3 4.16 kV Shutdown Board 3EC and 3ED inoperable.

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

Enter applicable conditions and required actions of Condition B, C, D, and G when Condition F results in no power source to a required 480 volt board.

F.1 Restore one 4.16 kV Shutdown Board to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OR In accordance with the Risk Informed Completion Time Program G. One or more required Unit 1 or 2 AC or DC Boards inoperable, for reasons other than Condition J.

G.1 Declare the affected SGT or CREV subsystem inoperable.

Immediately H. Required Action and associated Completion Time of Condition A, B, D, E, F, or J not met.

H.1 Be in MODE 3.

AND H.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours I.

Two or more electrical power distribution subsystems inoperable that result in a loss of function.

I.1 Enter LCO 3.0.3.

Immediately (continued)

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

LCO 3.0.4.a is not applicable when entering MODE 3.

CNL-25-041 Proposed Technical Specifications Bases Changes (Markups) for BFN Unit 1 (For Information Only)

(38 pages)

RPS Electric Power Monitoring B 3.3.8.2 (continued)

BFN-UNIT 1 B 3.3-272 Revision 0 BASES ACTIONS C.1 and C.2 (continued)

If any Required Action and associated Completion Time of Condition A or B are not met in MODE 1, 2, or 3, a plant shutdown must be performed. This places the plant in a condition where minimal equipment, powered through the inoperable RPS electric power monitoring assembly(s), is required and ensures that the safety function of the RPS (e.g.,

scram of control rods) is not required. The plant shutdown is accomplished by placing the plant in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

D.1 If any Required Action and associated Completion Time of Condition A or B are not met in MODE 4 or 5, with any control rod withdrawn from a core cell containing one or more fuel assemblies, the operator must immediately initiate action to fully insert all insertable control rods in core cells containing one or more fuel assemblies. Required Action D.1 results in the least reactive condition for the reactor core and ensures that the safety function of the RPS (e.g., scram of control rods) is not required.

If any Required Action and associated Completion Time of Condition A or B are not met in MODE 1, 2, or 3, the plant must be brought to a MODE in which overall plant risk is minimized. The plant shutdown is accomplished by placing the plant in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action C.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk-assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

RPS Electric Power Monitoring B 3.3.8.2 BFN-UNIT 1 B 3.3-274 Revision 0, 43, 123 March 22, 2020 BASES SURVEILLANCE SR 3.3.8.2.3 REQUIREMENTS (continued)

Performance of a system functional test demonstrates that, with a required system actuation (simulated or actual) signal, the logic of the system will automatically trip open the associated power monitoring assembly. Only one signal per power monitoring assembly is required to be tested. This Surveillance overlaps with the CHANNEL CALIBRATION to provide complete testing of the safety function. The system functional test of the Class 1E contactors is included as part of this test to provide complete testing of the safety function. If the contactors are incapable of operating, the associated electric power monitoring assembly would be inoperable.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1. FSAR, Section 7.2.3.2.

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

3. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants,"

December 2002.

ECCS - Operating B 3.5.1 (continued)

BFN-UNIT 1 B 3.5-9 Amendment 328 Revision 0 May 2, 2023 BASES ACTIONS A.1 (continued)

The 7 day Completion Time is based on a reliability study (Ref. 11) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times).

B.1 and B.2 If the inoperable low pressure ECCS subsystem cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

C.1 and C.2 If the HPCI System is inoperable and the RCIC System is immediately verified to be OPERABLE, the HPCI System must be restored to OPERABLE status within 14 days or in accordance with the Risk Informed Completion Time Program.

In this Condition, adequate core cooling is ensured by the OPERABILITY of the redundant and diverse low pressure ECCS injection/spray subsystems in conjunction with ADS.

Also, the RCIC System will automatically provide makeup water at most reactor operating pressures. Immediate verification of RCIC OPERABILITY is therefore required when HPCI is inoperable. This may be performed as an administrative check by examining logs or other information to determine if RCIC is If the inoperable low pressure ECCS subsystem cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 16) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk-assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

ECCS - Operating B 3.5.1 (continued)

BFN-UNIT 1 B 3.5-12 Revision 0, 123 March 22, 2020 BASES ACTIONS G.1 and G.2 (continued)

If any Required Action and associated Completion Time of Condition C, D, E, or F is not met, or if two or more ADS valves are inoperable, the plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reactor steam dome pressure reduced to 150 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

H.1 When multiple ECCS subsystems are inoperable, as stated in Condition H, the plant is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the HPCI System, CS System, and LPCI subsystems full of water ensures that the ECCS will perform properly, injecting its full capacity into the RCS upon demand. This will also prevent a water hammer following an ECCS initiation signal. One acceptable method of ensuring that the lines are full is to vent at the high points. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

If any Required Action and associated Completion Time of Condition C, D, E, or F is not met, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 16) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action G.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk-assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

I H.1 and H.2 If two or more ADS valves are inoperable, there is a reduction in the depressurization capability. The plant must be brought to a condition in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reactor steam dome pressure reduced to 150 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

ECCS - Operating B 3.5.1 BFN-UNIT 1 B 3.5-22 Revision 0, 112 October 24, 2018 BASES (continued)

REFERENCES

1. FSAR, Section 6.4.3.

2. FSAR, Section 6.4.4.

3. FSAR, Section 6.4.1.

4. FSAR, Section 6.4.2.

5. FSAR, Section 14.6.3.

6. FSAR, Section 14.6.5.

7. 10 CFR 50, Appendix K.

8. FSAR, Section 6.5.3.

9. 10 CFR 50.46.

10. TVA BFN System Design Criteria BFN-50-7032, Control Air System - Units 1, 2, and 3.

11. Memorandum from R. L. Baer (NRC) to V. Stello, Jr. (NRC),

"Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.

12. 10 CFR 50, Appendix A, GDC 34, GDC 35, GDC 36, and GDC 37.

13. ANP-3377P Revision 3, Browns Ferry Units 1, 2, and 3 LOCA Break Spectrum Analysis for ATRIUM 10XM Fuel (EPU), August 2015.

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

15. GE-NE-B13-01755-2, "Relaxation of ECCS Parameters, Revision 2, December 1996.

16. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants,"

December 2002.

RCIC System B 3.5.3 (continued)

BFN-UNIT 1 B 3.5-33 Revision 0 BASES ACTIONS A.1 and A.2 (continued) necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the HPCI System. If the OPERABILITY of the HPCI System cannot be verified, however, Condition B must be immediately entered. For certain transients and abnormal events with no LOCA, RCIC (as opposed to HPCI) is the preferred source of makeup coolant because of its relatively small capacity, which allows easier control of the RPV water level. Therefore, a limited time is allowed to restore the inoperable RCIC to OPERABLE status.

The 14 day Completion Time is based on a reliability study (Ref. 3) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (AOTs). Because of similar functions of HPCI and RCIC, the AOTs (i.e., Completion Times) determined for HPCI are also applied to RCIC.

B.1 and B.2 If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time, or if the HPCI System is simultaneously inoperable, the plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reactor steam dome pressure reduced to 150 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time, or if the HPCI System is simultaneously inoperable, the plant must be brought to a condition in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 5) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk-assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

RCIC System B 3.5.3 BFN-UNIT 1 B 3.5-38 Revision 0 BASES (continued)

REFERENCES

1. 10 CFR 50, Appendix A, GDC 33.

2. FSAR, Section 4.7.

3. Memorandum from R. L. Baer (NRC) to V. Stello, Jr. (NRC),

"Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.

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

5. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants,"

December 2002.

Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6.1.5 (continued)

BFN-UNIT 1 B 3.6-46 Revision 0 BASES ACTIONS C.1 (continued)

With one line with one or more vacuum breakers inoperable for opening, the leak tight primary containment boundary is intact.

The ability to mitigate an event that causes a containment depressurization is threatened if one or more vacuum breakers in at least one vacuum breaker penetration are not OPERABLE.

Therefore, the inoperable vacuum breaker must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This is consistent with the Completion Time for Condition A and the fact that the leak tight primary containment boundary is being maintained.

D.1 With two lines with one or more vacuum breakers inoperable for opening, the primary containment boundary is intact. However, in the event of a containment depressurization, the function of the vacuum breakers is lost. Therefore, all vacuum breakers in one line must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

This Completion Time is consistent with the ACTIONS of LCO 3.6.1.1, which requires that primary containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

E.1 and E.2 If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

E F

F If the vacuum breakers in one or more lines cannot be closed or restored to OPERABLE status within the required Completion Time D.1 If one line has one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening and they are not restored within the Completion Time in Condition C, the remaining breakers in the remaining lines can provide the opening function. The plant must be brought to a condition in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action C.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk-assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6.1.5 BFN-UNIT 1 B 3.6-48 Revision 0, 43, 123 March 22, 2020 BASES SURVEILLANCE SR 3.6.1.5.3 REQUIREMENTS (continued)

Demonstration of vacuum breaker opening setpoint is necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of 0.5 psid is valid. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1. TVA Calculation ND-Q0064-900040.

2.

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

3. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants,"

December 2002.

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.6 (continued)

BFN-UNIT 1 B 3.6-53 Revision 0 BASES APPLICABILITY In MODES 4 and 5, the probability and consequences of these (continued) events are reduced by the pressure and temperature limitations in these MODES; therefore, maintaining suppression chamber-to-drywell vacuum breakers OPERABLE is not required in MODE 4 or 5.

ACTIONS A.1 With one of the required vacuum breakers inoperable for opening (e.g., the vacuum breaker is not open and may be stuck closed or not within its opening setpoint limit, so that it would not function as designed during an event that depressurized the drywell), the remaining nine OPERABLE vacuum breakers are capable of providing the vacuum relief function. However, overall system reliability is reduced because a single failure in one of the remaining vacuum breakers could result in an excessive suppression chamber-to-drywell differential pressure during a DBA. Therefore, with one of the ten required vacuum breakers inoperable, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to restore at least one of the inoperable vacuum breakers to OPERABLE status so that plant conditions are consistent with those assumed for the design basis analysis. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is considered acceptable due to the low probability of an event in which the remaining vacuum breaker capability would not be adequate.

B.1 If a required suppression chamber-to-drywell vacuum breaker is inoperable for opening and is not restored to OPERABLE status within the required Completion Time, the plant must be brought to a condition in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 4) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk-assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.6 (continued)

BFN-UNIT 1 B 3.6-54 Revision 0 BASES ACTIONS B.1 (continued)

An open vacuum breaker allows communication between the drywell and suppression chamber airspace, and, as a result, there is the potential for suppression chamber overpressurization due to this bypass leakage if a LOCA were to occur. Therefore, the open vacuum breaker must be closed.

The required 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is allowed to close the vacuum breaker due to the low probability of an event that would pressurize primary containment. If vacuum breaker position indication is not reliable, an alternate method of verifying that the vacuum breakers are closed is to verify that the rate of increase in suppression chamber pressure is less than 0.25 inches of water per minute over a ten minute period at a differential pressure of at least 1.0 psi. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is considered adequate to perform this test.

C.1 and C.2 If any Required Action and associated Completion Time is not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

C D

D If the open suppression chamber-to-drywell vacuum breaker cannot be closed within the required Completion Time

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.6 BFN-UNIT 1 B 3.6-56 Revision 0, 43, 123 March 22, 2020 BASES SURVEILLANCE SR 3.6.1.6.3 REQUIREMENTS (continued)

Verification of the differential pressure required to open the vacuum breaker is necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of 0.5 psid is valid. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1. FSAR, Section 5.2.

2.

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

3.

Technical Requirements Manual.

4. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants,"

December 2002.

RHR Suppression Pool Cooling B 3.6.2.3 (continued)

BFN-UNIT 1 B 3.6-71 Amendment No. 241, 328 Revision 0 May 2, 2023 BASES ACTIONS B.1 (continued)

With two RHR suppression pool cooling subsystems inoperable, at least one inoperable subsystem must be restored to OPERABLE status within 7 days or in accordance with the Risk Informed Completion Time Program. In this condition, the remaining two RHR suppression pool cooling subsystems are adequate to perform the primary containment cooling function.

However, the overall reliability is reduced because a single failure could result in reduced or no primary containment cooling capability depending upon whether the two OPERABLE subsystems are in separate loops or the same loop. The 7 day Completion Time is acceptable in light of the redundant RHR suppression pool cooling capabilities afforded by the two OPERABLE subsystems and the low probability of a DBA occurring during this period.

C.1 With three or more RHR suppression pool cooling subsystems inoperable, the required subsystems must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In this condition, there is substantial loss of the primary containment pressure and temperature mitigation function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and because alternative methods to remove heat from the primary containment are available.

D C.1 If two RHR suppression pool cooling subsystems are inoperable and are not restored to OPERABLE status within the required Completion Time, the plant must be brought to a condition in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 4) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action C.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk-assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

two

RHR Suppression Pool Cooling B 3.6.2.3 (continued)

BFN-UNIT 1 B 3.6-72 Amendment No. 241 Revision 0, 123 March 22, 2020 BASES ACTIONS D.1 and D.2 (continued)

If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.2.3.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool cooling mode flow path provides assurance that the proper flow path exists for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR suppression pool cooling mode is manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

E E

of Condition C or D

RHR Suppression Pool Cooling B 3.6.2.3 BFN-UNIT 1 B 3.6-73 Revision 0, 81, 109 November 30, 2017 BASES SURVEILLANCE SR 3.6.2.3.2 REQUIREMENTS (continued)

Verifying that each RHR pump develops a flow rate 9000 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that pump performance has not degraded during the cycle. Flow is a normal test of centrifugal pump performance required by ASME OM Code (Ref. 2). This test confirms one point on the pump design curve, and the results are indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the INSERVICE TESTING PROGRAM.

REFERENCES

1. FSAR, Sections 5.2 and 14.6.3.

2. ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code).

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

4. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants,"

December 2002.

RHR Suppression Pool Spray B 3.6.2.4 (continued)

BFN-UNIT 1 B 3.6-78 Revision 0 BASES ACTIONS C.1 (continued)

With three or more RHR suppression pool spray subsystems inoperable, required subsystems must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In this condition, there is a substantial loss of the primary containment bypass leakage mitigation function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and because alternative methods to remove heat from primary containment are available.

D.1 and D.2 If any Required Action and the associated Completion Time cannot be met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.2.4.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool spray mode flow path provides assurance that the proper flow paths will exist for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, If the inoperable RHR suppression pool spray subsystem cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action D.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk-assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

RHR Suppression Pool Spray B 3.6.2.4 BFN-UNIT 1 B 3.6-79 Revision 0, 123 March 22, 2020 BASES SURVEILLANCE SR 3.6.2.4.1 (continued)

REQUIREMENTS sealing, or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR suppression pool spray mode is manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.2.4.2 This Surveillance is performed using air or water to verify that the spray nozzles are not obstructed and that flow will be provided when required. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1. FSAR, Sections 5.2 and 14.6.3.

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

3. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants,"

December 2002.

Secondary Containment B 3.6.4.1 (continued)

BFN-UNIT 1 B 3.6-104 Revision 0, 29, 125 January 26, 2022 BASES ACTIONS B.1 and B.2 (continued)

If secondary containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

If secondary containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 5) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk-assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate.

LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Secondary Containment B 3.6.4.1 BFN-UNIT 1 B 3.6-106 Revision 29, 123 Amendment No. 235 March 22, 2020 BASES SURVEILLANCE SR 3.6.4.1.3 and SR 3.6.4.1.4 REQUIREMENTS (continued)

The SGT System exhausts the secondary containment atmosphere to the environment through appropriate treatment equipment. To ensure that all fission products are treated, SR 3.6.4.1.3 verifies that the SGT System will rapidly establish and maintain a pressure in the secondary containment that is less than the lowest postulated pressure external to the secondary containment boundary. This is confirmed by demonstrating that two SGT subsystems will draw down the secondary containment to 0.25 inches of vacuum water gauge in 120 seconds. This cannot be accomplished if the secondary containment boundary is not intact. SR 3.6.4.1.4 demonstrates that two SGT subsystems can maintain 0.25 inches of vacuum water gauge at a stable flow rate 12,000 cfm. Both of these SRs are performed under neutral (5 mph) wind conditions. Therefore, these two tests are used to ensure secondary containment boundary integrity. Since these SRs are secondary containment tests, they need not be performed with each combination of SGT subsystems. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1. FSAR, Section 5.3.

2. FSAR, Section 14.6.3.

3. Deleted.

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

5. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants,"

December 2002.

SGT System B 3.6.4.3 (continued)

BFN-UNIT 1 B 3.6-117 Revision 0, 125 January 26, 2022 BASES (continued)

ACTIONS A.1 With one SGT subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status in 7 days. In this Condition, the remaining two OPERABLE SGT subsystems are adequate to perform the required radioactivity release control function. However, the overall system reliability is reduced because a single failure in the OPERABLE subsystem could result in the radioactivity release control function not being adequately performed. The 7 day Completion Time is based on consideration of such factors as the availability of the remaining two OPERABLE redundant SGT subsystems and the low probability of a DBA occurring during this period.

B.1 and B.2 If the SGT subsystem cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

If the SGT subsystem cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 5) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk-assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate.

LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SGT System B 3.6.4.3 (continued)

BFN-UNIT 1 B 3.6-119 Revision 0, 29, 125 January 26, 2022 BASES ACTIONS C.1 (continued)

If two or more SGT subsystems are inoperable, the SGT system may not be capable of supporting the required radioactivity release control function. Therefore, actions are required to enter LCO 3.0.3 immediately.

Therefore, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 5) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action C.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk-assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate.

LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SGT System B 3.6.4.3 BFN-UNIT 1 B 3.6-121 Revision 123 Amendment No. 235 March 22, 2020 BASES SURVEILLANCE SR 3.6.4.3.3 REQUIREMENTS (continued)

This SR verifies that each SGT subsystem starts on receipt of an actual or simulated initiation signal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.4.3.4 This SR verifies that the SGT decay heat discharge dampers are in the correct position. This ensures that the decay heat removal mode of SGT System operation is available. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1. 10 CFR 50, Appendix A, GDC 41.

2. FSAR, Section 5.3.3.7.

3. FSAR, Section 14.6.

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

5. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants,"

December 2002.

RHRSW System B 3.7.1 (continued)

BFN-UNIT 1 B 3.7-8 Revision 0, 73 January 3, 2013 BASES ACTIONS E.1 (continued)

With three or more required RHRSW pumps inoperable, the RHRSW System is not capable of performing its intended function. The requisite number of pumps must be restored to OPERABLE status within eight hours. The eight hour Completion Time is based on the Completion Times provided for the RHR suppression pool cooling and spray functions.

F.1 With three or more required RHRSW subsystems inoperable (e.g., one RHR heat exchanger inoperable in each of three or four separate RHRSW subsystems) for reasons other than inoperable RHRSW pumps, which are covered by separate Conditions, the RHRSW System is not capable of performing its intended function. The requisite number of subsystems must be restored to OPERABLE status within eight hours. The eight hour Completion Time is based on the Completion Times provided for the RHR suppression pool cooling and spray functions.

The Required Action is modified by a Note indicating that the applicable Conditions of LCO 3.4.7 be entered and Required Actions taken if the inoperable RHRSW subsystem results in inoperable RHR shutdown cooling. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

F G

E.1 If two RHRSW subsystems are inoperable or two RHRSW pumps in one or two subsystems are inoperable and not restored within the provided Completion Time, the plant must be brought to a condition in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 6) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action E.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate.

LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

RHRSW System B 3.7.1 (continued)

BFN-UNIT 1 B 3.7-9 Revision 0, 73, 123 March 22, 2020 BASES ACTIONS G.1 and G.2 (continued)

If the RHRSW subsystem(s) or the RHRSW pump(s) cannot be restored to OPERABLE status within the associated Completion Times, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.1.1 REQUIREMENTS Verifying the correct alignment for each manual and power operated valve in each RHRSW subsystem flow path provides assurance that the proper flow paths will exist for RHRSW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position, and yet considered in the correct position, provided it can be realigned to its accident position. This is acceptable because the RHRSW System is a manually initiated system.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

H H

of Condition F or G

RHRSW System B 3.7.1 BFN-UNIT 1 B 3.7-10 Revision 0, 112 October 24, 2018 BASES (continued)

REFERENCES

1. FSAR, Section 10.9.

2. FSAR, Chapter 5.

3. FSAR, Chapter 14.

4. (Deleted)

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

6. (Deleted)

NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants," December 2002.

EECW System and UHS B 3.7.2 (continued)

BFN-UNIT 1 B 3.7-14 Revision 0, 69, 123 March 22, 2020 BASES ACTIONS A.1 (continued)

The 7 day Completion Time is based on the redundant EECW System capabilities afforded by the remaining OPERABLE pumps, the low probability of an accident occurring during this time period and is consistent with the allowed Completion Time for restoring an inoperable DG.

B.1 and B.2 If the required EECW pump cannot be restored to OPERABLE status within the associated Completion Time, or two or more EECW pumps are inoperable or the UHS is determined inoperable, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.2.1 REQUIREMENTS Verification of the UHS temperature ensures that the heat removal capability of the EECW System is within the assumptions of the DBA analysis (Ref. 5) and is sufficient for removal of heat from supported equipment to maintain OPERABILITY of that equipment. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

C C

B.1 If the required EECW pump cannot be restored to OPERABLE status within the provided Completion Time, the plant must be brought to a condition in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref.

6) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

If two or more EECW pumps are inoperable or the UHS is determined inoperable

EECW System and UHS B 3.7.2 BFN-UNIT 1 B 3.7-16 Revision 69, 123 Amendment No. 235 March 22, 2020 BASES SURVEILLANCE SR 3.7.2.3 REQUIREMENTS (continued)

This SR verifies that the EECW System pumps will automatically start to provide cooling water to the required safety related equipment during an accident event. This is demonstrated by the use of an actual or simulated initiation signal. This SR includes a functional test of the initiation logic and a functional test and calibration of the EECW pump timers (both normal power and diesel power).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1. FSAR, Chapter 5.

2. FSAR, Chapter 14.

3. FSAR, Section 10.10.

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

5. FSAR, Section 14.6.3.3.2.3.

6. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants," December 2002.

CREV System B 3.7.3 (continued)

BFN-UNIT 1 B 3.7-22 Revision 0, 29, 67, 125 Amendment No. 246, 275 January 26, 2022 BASES ACTIONS D.1 (continued) which has determined that the CRE 30 day dose after the DBA does not exceed 5 rem (TEDE) without credit for either the HEPA filter or the charcoal adsorbers, and the capability of the remaining OPERABLE CREV subsystem.

E.1 and E.2 If the inoperable CREV subsystem or the CRE boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 1, 2, or 3, if the inoperable CREV subsystem or the CRE boundary cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE that minimizes overall plant risk. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 11) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action E.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the accountability of entering MODE 3, and establishment of risk management actions, if appropriate.

LCO 3.0.4. is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

CREV System B 3.7.3 (continued)

BFN-UNIT 1 B 3.7-23 Revision 0, 29, 67, 125 Amendment No. 246, 275 January 26, 2022 BASES ACTIONS F.1 (continued)

If both CREV subsystems are inoperable for reasons other than Condition B or Condition C, the CREV System may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

If both CREV subsystems are inoperable for reasons other than Condition B or Condition C, the CREV System may not be capable of performing the intended function. Therefore, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 11) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action F.1 is modified by a Note that states that LCO 3.0.4a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

CREV System B 3.7.3 BFN-UNIT 1 B 3.7-25b Revision 67 Amendment 235, 275 August 10, 2012 BASES (continued)

REFERENCES

1. FSAR, Section 10.12.

2. FSAR, Chapter 10.

3. FSAR, Chapter 14.

4. FSAR, Section 14.6.

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

6. NRC Regulatory Guide 1.196, Control Room Habitability At Light-Water Power Reactors, January 2007.

7. NEI 99-03, Control Room Habitability Assessment, June 2001.

8. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability, (ADAMS Accession No. ML040300694).

9. FSAR, Chapter 10.12.5.3, Toxic Gas Protection.

10. TVA Design Output Calculation NDQ0031920075, Control Room and Offsite Dose Due to a LOCA, Revision 21.

11. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants," December 2002.

Control Room AC System B 3.7.4 (continued)

BFN-UNIT 1 B 3.7-29 Revision 0 BASES ACTIONS B.1, B.2.1, B.2.2 (continued)

With both Unit 1 and 2 control room AC subsystems inoperable, cooling by a Unit 1 and 2 control AC subsystem must be restored without delay.

Until Unit 1 and 2 control room AC OPERABILITY is re-established, an alternate method of control room cooling must be placed in service within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Alternate means should be taken as necessary to maintain the Unit 1 and 2 control room temperature during this Condition. These include, but are not limited to, the use of the emergency chiller, the Unit 3 Control Room AC System and the Relay Room AC System. A Completion Time of 7 days (Required Action B.2.2) is provided to restore at least one Unit 1 and 2 control room AC subsystem to OPERABLE status. A 7 day time period is allowed to restore the function based on the low probability of an event occurring that requires control room isolation, the alternate method of cooling, and the potential for decreased safety if the unit operator's attention is diverted from the actions necessary to restore control room AC to the actions associated with taking the unit to shutdown within this time limit.

C.1 and C.2 In MODE 1, 2, or 3, if the inoperable Unit 1 and 2 control room AC subsystem(s) cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE that minimizes risk. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 1, 2, or 3, if the inoperable Unit 1 and Unit 2 control room AC subsystem(s) cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE that minimizes overall plant risk. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action C.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are a part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

Control Room AC System B 3.7.4 BFN-UNIT 1 B 3.7-31 Revision 123 Amendment No. 235 March 22, 2020 BASES (continued)

SURVEILLANCE SR 3.7.4.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the control room heat load assumed in the safety analyses. The SR consists of a combination of testing and calculation. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1. FSAR, Section 10.12.

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

3. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants," December 2002.

AC Sources - Operating B 3.8.1 (continued)

BFN-UNIT 1 B 3.8-24 Revision 0 BASES ACTIONS H.1 (continued)

With two or more DGs inoperable, an assumed loss of offsite electrical power may result in insufficient standby AC sources available to power the minimum required ESF functions. Since the offsite electrical power system may be the only source of AC power for the majority of ESF equipment at this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown. (The immediate shutdown could cause grid instability, which could result in a total loss of AC power.) Since any inadvertent unit generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.

According to Regulatory Guide 1.93 (Ref. 6), with all DGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

I.1 and I.2 If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 16) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action I.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

AC Sources - Operating B 3.8.1 BFN-UNIT 1 B 3.8-38 Revision 0, 123 March 22, 2020 BASES (continued)

REFERENCES

1. 10 CFR 50, Appendix A, GDC 17.

2. FSAR, Chapter 8.

3. Safety Guide 9.

4. FSAR, Chapter 6.

5. FSAR, Chapter 14.

6. Regulatory Guide 1.93.

7. Generic Letter 84-15.

8. Deleted.

9. ANSI C84.1, 1982.

10. FSAR, Section 14.6.3.

11. IEEE Standard 308.

12. FSAR, Section 8.5, Table 8.5-6.

13. FSAR, Section 8.5.2.

14. TVA Design Criteria BFN-50-7082.

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

16. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants," December 2002.

DC Sources - Operating B 3.8.4 (continued)

BFN-UNIT 1 B 3.8-63 Revision 0 BASES ACTIONS B.1 and B.2 (continued)

If the Unit or Shutdown Board DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 4 is consistent with the time required in Regulatory Guide 1.93 (Ref. 6).

C.1 If a DG DC electrical power subsystem is inoperable, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable. This declaration also requires entry into applicable Conditions and Required Actions for an inoperable DG, LCO 3.8.1, "AC Sources - Operating."

D.1 Required Action D.1 is intended to provide assurance that a loss of Unit 3 Shutdown Board DC electrical power subsystem 3EB does not result in a complete loss of safety function of critical systems (i.e., CREVS). With Unit 3 Shutdown Board DC electrical power subsystem 3EB inoperable, the CREVS train supported by that shutdown board is inoperable. Therefore, the associated CREVS subsystem must be declared inoperable immediately, and the ACTIONS in the appropriate system Specification taken.

If the Unit or Shutdown Board DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 12) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate.

LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

DC Sources - Operating B 3.8.4 BFN-UNIT 1 B 3.8-68 Amendment No. 235 November 30, 1998 BASES (continued)

REFERENCES

1. 10 CFR 50, Appendix A, GDC 17.

2. Regulatory Guide 1.6.

3. IEEE Standard 308.

4. FSAR, Sections 8.5 and 8.6.

5. FSAR, Chapters 6 and 14.

6. Regulatory Guide 1.93.

7. IEEE Standard 450-1995.

8. Regulatory Guide 1.32, February 1977.

9. Deleted.

10. IEEE Standard 485, 1983.

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

12. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants," December 2002.

Distribution Systems - Operating B 3.8.7 (continued)

BFN-UNIT 1 B 3.8-100 Revision 0, 33, 123, 132 July 27, 2022 BASES ACTIONS G.1 and G.2 (continued)

If the inoperable distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

H.1 Condition H corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost. When more than one AC or DC electrical power distribution subsystem is lost, for reasons other than Condition I, and this results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

I.1 Condition I is preceded by a note stating that the Condition is only applicable when the compensatory actions of Section 3 of the enclosure to Reference 5 are taken, electric board room temperatures are maintained 104°F, and on a one-time basis for installation and testing of the Unit 3 Control Bay Chiller Cross-tie before October 1, 2025. This Condition, where two or more electrical power distribution subsystems are inoperable due to installation and testing of the Unit 3 Control Bay Chiller Cross-tie, provides 9 days to restore the affected electrical power distribution subsystems to OPERABLE status.

If the inoperable distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 6) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action G.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate.

LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Distribution Systems - Operating B 3.8.7 BFN-UNIT 1 B 3.8-101 Revision 0, 132 July 27, 2022 BASES (continued)

SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the AC and DC electrical power distribution subsystem is functioning properly, with the buses energized. The verification of proper voltage availability on the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1. FSAR, Chapter 6.

2. FSAR, Chapter 14.

3. Regulatory Guide 1.93, December 1974.

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

5. TVA Letter to NRC, CNL-21-020, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application Requesting NRC Prior Approval of a Proposed Chilled Water Crosstie Modification to Support System Operability, dated November 5, 2021 (ML21309A038).

6. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants," December 2002.

CNL-25-041 List of Regulatory Commitments CNL-25-041 E2 - 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Tennessee Valley Authority (TVA) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Amber V. Aboulfaida, Senior Manager, Fleet Licensing.

REGULATORY COMMITMENTS DUE DATE/EVENT 1.

TVA will follow the guidance established in Section 11 of NUMARC 93-01, Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Nuclear Management and Resource Council.

Ongoing 2.

TVA will follow the guidance established in TSTF-IG-05-02, Revision 2, Implementation Guidance for TSTF-423, Revision 1, Technical Specifications End States, NEDC-32988-A.

Implement with amendment, when TS Required Action End State remains within the APPLICABILITY of TS

v t e Letter Sequence Request
EPID:L-2025-LLA-0070, TSTF-423 (Open)
Initiation Request Acceptance Administration Questions Answers Results Approval, Approval Other:
MONTHYEAR2025-12-18 [Table View]

CNL-25-041, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423-A, Revision 1, Technical Specifications End States, NEDC-32988-A, Using the Consolidated Line.

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