CNL-25-038, Application to Revise Technical Specifications to Adopt TSTF-597-A, Eliminate LCO 3.0.3 Mode 2 Requirement
| ML25171A008 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/20/2025 |
| From: | Hulvey K Tennessee Valley Authority |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| CNL-25-038 | |
| Download: ML25171A008 (1) | |
Text
10 CFR 50.90 1101 Market Street, Chattanooga, Tennessee 37402 CNL-25-038 June 20, 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 - Application to Revise Technical Specifications to Adopt TSTF-597-A, "Eliminate LCO 3.0.3 Mode 2 Requirement" In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.90, Tennessee Valley Authority (TVA) is submitting a request for an amendment to the Technical Specifications (TS) for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3.
TVA requests adoption of TSTF-597-A, Eliminate LCO 3.0.3 Mode 2 Requirement, which is an approved change to the Standard Technical Specifications (STS), into the BFN Units 1, 2, and 3 TS. TSTF-597-A revises Limiting Condition of Operation (LCO) 3.0.3 to eliminate the requirement to enter Mode 2.
The enclosure provides a description and assessment of the proposed change. Attachment 1 provides the existing BFN TS pages marked to show the proposed changes. Final retyped TS pages will be provided to the Nuclear Regulatory Commission (NRC) upon their request. provides the existing BFN Unit 1 TS Bases pages marked to show revised text associated with the proposed TS changes (changes to BFN Units 2 and 3 TS Bases pages 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.
TVA requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within 90 days.
U. S. Nuclear Regulatory Commission CNL-25-038 Page 2 June 20, 2025 In accordance with 10 CFR 50.91, a copy of this application with attachments is being provided to the designated Alabama official.
There are no new regulatory commitments associated with this submittal. Please address any questions regarding this to Amber V. Aboulfaida, Senior Manager, Fleet Licensing, at avaboulfaida@tva.gov.
I declare under penalty of perjury that the foregoing is true and correct. Executed on this 20th day of June 2025.
Respectfully, Kimberly D. Hulvey General Manager, Nuclear Regulatory Affairs & Emergency Preparedness
Enclosure:
Description and Assessment of the Proposed Change cc (Enclosure):
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: 2025.06.20 07:45:15
-04'00'
Enclosure CNL-25-038 E1 of 4 Description and Assessment of the Proposed Change
Subject:
Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application to Revise Technical Specifications to Adopt TSTF-597-A, Eliminate LCO 3.0.3 Mode 2 Requirement CONTENTS
1.0 DESCRIPTION
............................................................................................................ 2
2.0 ASSESSMENT
............................................................................................................ 2 2.1 Applicability of Safety Evaluation............................................................................ 2 2.2 Variations................................................................................................................ 2
3.0 REGULATORY ANALYSIS
......................................................................................... 2 3.1 No Significant Hazards Consideration Analysis...................................................... 2 3.2 Conclusion............................................................................................................... 4
4.0 ENVIRONMENTAL CONSIDERATION
...................................................................... 4 Attachments:
- 1.
Proposed TS Changes (Markups) for BFN Units 1, 2, and 3
- 2.
Proposed TS Bases Changes (Markups) for BFN Unit 1 (For Information Only)
Enclosure CNL-25-038 E2 of 4 Description and Assessment of the Proposed Change
1.0 DESCRIPTION
Tennessee Valley Authority (TVA) requests adoption of TSTF-597-A, Eliminate LCO 3.0.3 Mode 2 Requirement, which is an approved change to the Standard Technical Specifications (STS), into the Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3 Technical Specifications (TS). TSTF-597-A revises Limiting Condition of Operation (LCO) 3.0.3 to eliminate the requirement to enter Mode 2.
2.0 ASSESSMENT
2.1 Applicability of Safety Evaluation TVA has reviewed the safety evaluation for TSTF-597 provided to the Technical Specifications Task Force in a letter dated December 26, 2024. This review included the NRC staffs evaluation, as well as the information provided in TSTF-597. TVA has concluded that the justifications presented in TSTF-597 and the safety evaluation prepared by the NRC staff are applicable to BFN Units 1, 2, and 3 and justify this amendment for the incorporation of the changes to the BFN TS.
2.2 Variations TVA is not proposing any variations from the TS changes described in TSTF-597-A or the applicable parts of the NRC staffs evaluation.
The BFN TS permits a longer Completion Time to enter Mode 2 than the 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> in the STS.
This change was approved by the NRC in Amendments Nos. 239, 266, and 226 for BFN Units 1, 2, and 3, respectively. The different Completion Time does not affect the applicability of the proposed change to the BFN TS.
The BFN TS does not contain the LCO 3.0.3 Reviewers Note regarding the Mode 2 time requirement that is part of the STS. Therefore, removal of the note as described in TSTF-597-A is not applicable to BFN.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Analysis Tennessee Valley Authority (TVA) requests adoption of Technical Specifications Task Force (TSTF)-597-A, Eliminate LCO 3.0.3 Mode 2 Requirement, which is an approved change to the Standard Technical Specifications (STS), into the Browns Ferry Nuclear Plant, Units 1, 2, and 3 Technical Specifications (TS). TSTF-597-A revises Limiting Condition of Operation (LCO) 3.0.3 to eliminate the requirement to enter Mode 2.
TVA has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in Title 10 of the Code of Federal Regulations (10 CFR) 50.92, Issuance of amendment, as discussed below.
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Enclosure CNL-25-038 E3 of 4 Response: No The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode 2. The time required to shut down the plant after entering LCO 3.0.3 is not an initiator of any accident previously evaluated. Under the proposed change, the TS continue to require the plant to shut down and enter Mode 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. The consequences of any accident previously evaluated during the revised LCO 3.0.3 shutdown requirements are no different than the consequences of the same accident during the existing times.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode 2. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the current plant operating practice for all other TS required shutdowns.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode 2. The proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, TVA concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.
Enclosure CNL-25-038 E4 of 4 3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
4.0 ENVIRONMENTAL CONSIDERATION
A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.
However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a 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 amendment 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 amendment.
Enclosure CNL-25-038 Proposed Technical Specifications Changes (Markups) for Browns Ferry Nuclear Plant, Units 1, 2, and 3 (3 pages)
LCO Applicability 3.0 (continued)
BFN-UNIT 1 3.0-1 Amendment No. 234, 239 November 21, 2000 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7.
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:
a.
MODE 2 within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />; b.
MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and c.
MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1, 2, and 3.
D E
LCO Applicability 3.0 (continued)
BFN-UNIT 2 3.0-1 Amendment No. 253, 266 November 21, 2000 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7.
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:
a.
MODE 2 within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />; b.
MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and c.
MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1, 2, and 3.
D E
LCO Applicability 3.0 (continued)
BFN-UNIT 3 3.0-1 Amendment No. 212, 226 November 21, 2000 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7.
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:
a.
MODE 2 within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />; b.
MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and c.
MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1, 2, and 3.
D E
Enclosure CNL-25-038 Proposed Technical Specifications Bases Changes (Markups) for Browns Ferry Nuclear Plant, Unit 1 (For Information Only)
(1 page)
LCO Applicability B 3.0 (continued)
BFN-UNIT 1 B 3.0-5 Revision 0 Amendment 326 May 25, 2022 BASES LCO 3.0.3 The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to (continued) be in MODE 4 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for entering the next lower MODE applies. If a lower MODE is entered in less time than allowed, however, the total allowable time to enter MODE 4, or other applicable MODE, is not reduced. For example, if MODE 2 is entered in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for entering MODE 3 is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, because the total time for entering MODE 3 is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to enter a lower MODE of operation in less than the total time allowed.
In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.6, "Spent Fuel Storage Pool Water Level." LCO 3.7.6 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel storage pool."
For example, if MODE 3 is entered in 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />, then the time allowed for entering MODE 4 is the next 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />, because the total time for entering MODE 4 is not reduced from the allowable limit of 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.