ML20199D547

Proposed Tech Specs Section 3.0, Limiting Condition for Operation (LCO) Operability & Section 4.0, Design Changes

ML20199D547
Person / Time
Site:	Browns Ferry
Issue date:	11/14/1997
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20199D526	List: ML20199D520 ML20199D547
References
NUDOCS 9711200360
Download: ML20199D547 (66)

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LC0 Applicability-3.0 3.0 LC0 APPLICABILITY Applicability for an unlimited pericd of time. This LC0 3.0. 4 _ (continued) Specification shall not prevent 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. Exceptions to this Specification are stated in the individual Specifications. LC0 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, and 3. LCO_ 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be-returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform i l the testing required to demonstrate OPERABILITY. 1 LC0 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the C Mitions and Required Actions associated with this supported system are l not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO.3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification-5.5.ll, " Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appro>riate Conditions and Required Actions of the LCO in w11ch the loss of safety function exists are required to be entered. L L (continued) BFN-UNIT I 3.0-2 Amendment *R2 l

BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS-SECTION 3.0 LIST OF REVISED PAGES UNIT 2 ITS SECTIONS Replaced page 3.0-2 *R1 with page 3.0-2 'R2 e .m

~ LCO Applicability 3c0 3.0 LC0 APPLICABILITY LC0 3.0.4 Applicability for an unlimited period of time. This 1 (continued) Specification shall not prevent changes in MODES or other-1 specified conditions in the Applicability that are required j to comply with ACTIONS or that are a part of a shutdown of the unit. Exceptions to this Specification are stated in the individual Specifications. LCO 3.0.4 is only applicable for entry into a MODE or other - specified condition in the Applicability in MODES 1, 2, and 3. LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to starvice under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LC0 3.0.2 for the system returned to service under administrative control to perform l the testing required to demonstrate OPERABILITY. LCO 3.0.6 When a supported system LC0 is not met solely due to a support system LC0 not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with L l Specification 5.5.11, " Safety Function Detensination Program (SFDP). If a loss of safety function is determined to exist by this program, the appro>riate Conditions and Required Actions of the LC0 in which the loss of safety function exists are required to be entered. I l i l (continued) j BFN-UNIT 2 3.0 2 Amendment *R2 L

. i i i BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICA'110NS L: -- SECTION 3.0 L LIST OF REVISED PAGES : - 1 l i UNIT 3 ITS SECTIONS;.

Replaced page 3.0 2 ?R1 with page 3,0 2 *R2 -

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LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 Applicability for an unlimited period of time. This (continued) Specificattor, shall not prevent changes in MODES or other specified conditions in the Applicability that are require to comply with ACTIONS or that are a part of a shutdown w: the unit. Exceptions to this Specification cre stated in the individual Specifications. LCO 3.0.4 is only applicable for entry into a MOOL or other specified condition in the Applicability in MODES 1, 2, and 3. LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system i returned to service under administrative control to perform l the testing required to demonstrate OPERABILITY. l l LCO 3.0.6 When a supported system LCO is not met solely due to a support system LC0 not being u t, the Coaditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with ,o Specification 5.5.11, " Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the approariate Conditions and Required Actions of the LCO in w11ch the loss of safety function exists are required to be entered. (continued) l BFN-UNIT 3 3.0-2 Amendment *R2

O BROWNS FERRY NUCLEAR PLANT. IMPROVED TECHNICAL SPECIFICATIONS. SECTION 3.0 LIST OF REVISED PAGEF UNIT I ITS BASES SECTIONS Replaced page B 3.0-7 witti page 3.0 7_*R2 t Y

LC0 Applicability B 3.0 i BASES LC0 3.0.4 variable within limits) and restoring compliance.with the-(continued) affected LCO. LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been: removed froa service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with i the applicable Required Action (s)) to allow the performance l of required testing to demonstrate: a. The OPERABILITY of the equipment being returned to i service; or b. The OPERABILITY of other equipment. The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to l perfom the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing. An example of demonstrating the OPERABILITY of other equiment is taking an inoperable channel or trip systee out of_ tie tripped condition to prevent the trip function from o l occurring during the performance of required testing on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of i l required testing on another channel in the same trip system. 1 (continued) BFN-UNIT 1 B 3.0-7 Amendeant *R2 .,i, -,,v.-

BROWNS FERRY NUCLEAR PLANT. IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.0 LIST OF REVISED PAGES UNIT 2 ITS BASES SECTIONS Replaced page B 3.0-7 with page 3.0 7 *R2 s

LC0 Applicability B 3.0 .1 BASES LC03.0.4. Variable within limits) and restoring compliance with-the .(continued) affected LCO. LC0 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable ~ to comply with i ACTIONS. The sole purpose of this Specification is to provide an excwption to LC0 3.0.2 (e.g., to not comply with the applicable Required Action (s)) to allow the performance l of required testing to demonstrate: The OPERABILITY of the equipment being returned to a. L service; or b. The OPERABILITY of other equipment. i The administrative controls ensure the time the equipment is t returned to service in conflict with the requirements of the l ACTIONS is limited to the time absolutely necessary to l-l perform the requiced testing to demonstrate OPERABILITY. This Specification does not provide time to perform any l other preventive or corrective maintenance. An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing. An example of demonstrating the OPERABILITY of other equi ment is taking an inoperable channel or trip system out L of tie tripped condition to prevent the trip function from l occurring during the perfomance of required testing on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and l indicate the appropriate response during the performance of l required testing on another chann66 in the same trip system. (continued) BFN-UNIT 2 B 3.0-7 Amendment *R2 l l

.,y . ~.. _ _. ~. -., c- ) BROWNS FERRY NUCLEAR PL NTi MPROVED TECHNICAL SPECIFICATIONS ' ~ l L SECTION 3.0 :- - LIST OF REVISED PAGESi og j L UNIT 3 ITS BASES SECTIONS - I -- Replaced page B 3.0-7 with page 3.0 7 *R2

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m _-.. _ 7 --- LC0 Applicability B 3.0 BASES LCO 13.0.4 ' variable within limits) and restoring compliance with the (continued) affected LC0. LC0 3.0.5 LC0 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to~ provide an exception to LCO 3.0.2 (e.g., to not comply with-the applicable Required Action (s)) to allow the performance l of required testing to demonstrate: The OPERABILITY of the equipment being returned to a. service; or b. The OPERABILITY of other equipment. The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to l perform the required testing to demonstrate OPERABILITY. This Specification does not reovide time to perform any other preventive or corrective maintenance. An-example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolttion valve that has been closed to comply with Required Actions and must be reopened to perform the required testing. An example of demonstrating the OPERABILITY of other equi > ment is taking an inoperable channel or trip system out of tie tripped condition to prevent the trip function fron l occurring during the performance of required testing on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of l_ required testing on another channel in the same trip system. 4 (continued) BFN-UNIT 3_ B 3.0-7 Amendment *R2 E 1 ..e.-w,_ .m en w,,,n. .,--.g,. er-s y-- - _ - - ~ o 4

< = = - + BROWNS FERRY NUCLEAR PLANT IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.0 LIST OF REVISED PAGES JUST'FICATION FOR CHANGES TO CURRENT TECH SPECS replaced pages [1 of 6 through 6 of 6 Revision 1] with pages [l of 6 through 6 of 6 Revision 2]

t l. ? JUSTIFICATION FOR CHANGES l SECTION 3.0 - LC0 APPLICABILITY 8EllllllIRELL.Gli8llEl The Bases for Section 3.0 are being added in accordance with applicable Al ~ Bases from NUREG-1433. The individual changes made to add'LC0 3.0 and-SR 3.0 Technical Speelfication provisions provide thelustifications necessary to substantiate the contents of these Bases. A2 LC0 3.0.6 contains new provisions over present Technical-Specification requirements. These new provisions provide guidance regarding the appropriate actions to be taken when a single inoperability (e.g., a - support system) also results in the inoperability of one or more related systems-(e.g., supported systcs(s)). In the existing Technical Specifications, along with their intent and interpretation provided by the NRC over-the years, there is agi an unambiguous approach to the-combined support / supported system inoperability. Guidance provided.in the June 13, 1979, NRC memorandum from Brian K. Grimes (Assistant Director for Field Coordination) would indicate an intent / interpretation consistent with the proposed LC0 3.0.6 - without the necessity of also requiring the additional actions:of a Safety Function Determination Program. That is,-only the inoperable support system actions need be taker.. Guidance provided by the NRC in their April 10, 1980, letter to all Licensees regarding the definition of operability and the impact of a support system on the remainder of the Technical Specifications, would indicate a similar philosophy of nnt taking actions for the inoperable :upported equipment. However, in this case, additional actions similar to the proposed Safety Function Detemination Program actions, were addressed and required. Generic Letter 91-18 and a plain-English reading of the existing STS provide an interpretation that failure to perfore a required function, even as a result of a Technical Specification support system, requires all associated action be taken. Considering the history of disagreement and misunderstandings in this area, the BWR Standard Technical Specification, NUREG-1433, was developed with-industry input and approval of the NRC to include LC0 3.0.6. The present custon BFN Technical Specifications do not contain specific Action Statements as presented in current STS plants. The present-BFN Technical Specification provisions are usually left to interpretation as te supported system operability when a support system is inoperable unless specific direction is contained in the Technical Specification. Since the addition of LC0 3.0.6 to the BFN Technical Specifications will clarify existing ambiguities and maintain actions. i within the realm of previous interpretations, this new provision is deemed to be administrative in nature. BFN-UNITS 1. 2, & 3-1 of 6 Revision 2

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4 I JUSTIFICATION FOR CHANGES I SECTION 3.0 - LCO APPLICABILITY ADNINISTRATIVE CHANGES (continued)- A3-LC0 3.0.7 is.a new requirement 1thatTis not presently addressed in the CFN TSs. Present BFN TSs do not contain special operations LCOs and, as such,-do not need LC0 3.0.7 allowances. LC0 3.0.7 specifies that'- compliance with special operations-LCOs is optional, but if used,- then-the actions of the special operations LCOs shall be met. The applicability of a special operations LC0 represents a condition not -necessarily in compliance with the nomal recuirements of the TS. A special operation may be performed either un<er the provisions of the appropriate special operations LCO or under the other applicable TS requirements. When a special o)erations LC0 tequires another LC0 to be' met, only the requirements of tte LCO statement are required to be met 3 regardless of that LCOs applicability. The surveillances of the other LC0 are not.aquired tc be met, unless specified in the Special l Operations LLO. This Specification eliminates the confusion which would otherwise exist as to w11ch'LCOs apply during the performance of a special test or operation. This change is considered to provide administrative controls for the use of Special Operations LCOs and, as such, this change is administrative in nature.. l A4 Editorial rewording, reformatting and renumbering is made consistent with the BWR Standard Technical Specifications, NUREG-1433. During the development of SR 3.0.1, certain wording preferences or language conventions were adopted which resulted in no technical changes (either I actual or interpretational) to the Technical Specifications. The second sentence of SR 3.0.1 has been worded to clarify an existing intent that is not explicitly stated. The provision states that failure to meet a Surveillance Requirement can occur-during performance of the SR or between performances of the SR and either case shall result in failure to meet the LCO. The last sentence of SR 3.0.1 is clarified by adding the phrase "or variables outside specified limits." This addition is necessary since all LCOs do not deal exclusively with equipment operability, AS Editorial rewording for SR 3.0.2 is made consistent with the BWR e Standard Technical Specifications, NUREG-1433, which has resulted in no technical changes (either actual or interpretational) to the basic application of the 25% extension to routine surveillances. Also, the sentence _" Exceptions to thete requirements are stated in the individual Specifications" is added to acknowledge the explicit use of exceptions in various surveillances. These changes proviA consistency of wording and clarity for understanding. No. technical changes (either actual or interpretational) to the Technical Specifications are intended by these changes. BFN-UNITS 1, 2, & 3 2 of 6 Revision 2

L JUSTIFICATION FOR CHANGE 3 SECTION 3.0 - LC0 APPLICABILIfY IggMICAL CHANGE - NORE RESTRICTIVE The itent. identified as More Restrictive (MR) ar6 those which contain requirements that are more restrictive than Current Technical Specifications. These MR requirements are based on the Standard Technical Specifications for BWR/4, NUREG-1433, modified to reflect BFN specific design, and have been determined to be appropriate and safe for BFN based on a review of current design bases. r M1 Present BFN Technical Specifications do not contain specific guidance such as proposed in LCO 3.0.1. Present individual Technical Specification requirements are understood to apply as stated in each individual specification without the necessity of a motherhood statement. The adoption of NUREG-1433 for BFN will add requirements not presently in the Technical Specifications and, as such, potentially more restrictive provisions. Proposed LCO 3.0.1 contains exceptions to LC0 .?.0.2 and LCO 3.0.7. These exceptions will state when it is acceptable for the LCO to not be met during the Modes or other specified conditions in the Applicability. The exception to LCO 3.0.2 is necessary since LC0 3.0.2 addresses the condition of meeting the associated Actions when not meeting a LC0. The exception to LCO 3.0.7 is necessary since LCO 3.0.7 provides special guidance that will allow Special Operations Technical L Specifications to govern over the LCOs in Sections 3.1 through 3.9. l, l The addition of LCO 3.0.1 is a more restrictive change since mode dependent applicability requirements are formally established for LCOs. However, to consistently implement ITS, it is necessary to adopt the provisions of LCO 3.0.1. Therefore, BFN is agreeable to the c)ange and does not consider the addition to establish undue limitations or g re:trictions on plant operations. M2 Present BFN Technical Specifications do not contain the provisions of LCO 3.0.2. LCO 3.0.2 requires that upon failure to meet an LCO, that the required Actions shall be met. Present BFN custom Technical Specifications do not contrin a specific Action Statement-section. The Actions for the present BFN Technical Specifications are contained within paragraphs that also contain the LC0 and Applicability. Exceptions to LCO 3.0.2 are as provided in LC0 3.0.5 and LC0 3.0.6. These exceptions are necessary to allow systems to be returned to service under administrative control to perform the testing recuired to demonstrate operability per LCO 3.0.5, and to allow a supportec system 4 to be considered operable and its Actions not to be taken, solely due to a support system inoperability per LCO 3.0.6. LC0 3.0.2 also contains a provision such that. completion of the Required Actions is not required, unless othenvise stated, if the provisions of a LC0 are met or are no longer applicable. Since the present BFN TSs do not contain provisions siellar to LC0 3.0.2, this proposed change may result in potentially more restrictive requirements, i L BFN-UNITS 1, 2, 1 3 3 of 6 Revision 2

j JL'STIFICATION FOR CHANGES SECT 10N 3.0 - LC0 APPLICABILITY TECHNICALCHANGE-NORERESTRICTIVE(continued) The addition of LCO 3.0.2 is considered a more restrictive change since existing CTS do not specifically contain an analogous provision. However, to consistently im>1ement ITS, it is necessary to ado >t the provisions of LC0 3.0.2. Tierefore, BFN is agreeable to the c1ange and does not consider the addition to establish undue limitations or restrictions on plant operations. M3 The present BFN TSs do not contain provisions similar to proposed LCO 3.0.4. LCO 3.0.4 prohibits entry into a mode or other specified condition, when a LCO is not met, unless the associated actions to be entered pemit continued operation for an unlimited period of time. The provisions of LCO 3.0.4 will not prevent changes in modes or other specified conditions in the a)plicability that are required to comply with actions. In addition, tie provisions of LCO 3.0.4 will not prevent changes in modes or other specified conditions in the applicability that result from a normal shutdown. Any exceptions to this specification are stated in individual specifications. The addition of this specification ts BFN TSs represents a potentially more cestrictive change. The addition of LCO 3.0.4 is considered a more restrictive change since existing CTS do not specifically contain an analogous provision. However, to consistently im)1ement ITS, it is necessary to adopt the provisions of LCO 3.0.4. Tierefore, BFN is agreeable to the change and does not consider the addition to establish undue limitations or l restrictions on plant operations. M4 The sentence "For Frequencies specified as "once," the above interval extension does not ap)1y" is proposed to be added. The interval extension concept is )ased on scheduling flexibility for repetitive performances, and these "once" surveillances are not repetitive in nature and essentially have no interval as measured from the previous performance. The nature of these SRs precludes the ability to extend their performances, and is therefore a more restrictive requirement. The existinsi specification can be interpreted to allow the extension to apply to all surveillances. M5 Present BFN TSs do not contain provisions similar to proposed SR 3.0.4. SR 3.0.4 estabtishes the requirement that all applicable SRs must be met before entry into a mode or other specified condition in the applicability. This specification ensures that system and component operability requirements and variable limits are met before entry into modes or other specified conditions in the applicability for which these systems and components ensure safe operation of the unit. This specification applies to changes in modes or other soecified conditions in the applicability associated with unit startup. .hc provisions of SR 3.0.4 will not prevent changes in modes or other specified conditions in the applicability that are required to comply with actions or that are part of a unit shutdown. BFN-UNITS 1, 2, & 3 4 of 6 Revision 2

1 w i JUSTIFICATION FOR CHANGES SECTION 3.0 i LC0 APPLICABILITY TECittICAL CHANGE - LESS RESTRICTIVE L1 Present Definition 1.0.C.1 contains the requirements typically-referred to as LC0 3.0.3 in the Standard Technical Specifications. The changes to present requirements include the following: i One additional hour for. p1a'nt shutdown is included over present r provisions. This additional hour was included in the STS to allow 4 time to initiate a plant shutdown. The additional hour is included in the ICTS to allow initiation of the plant shutdown and - 1 is included in the ISTS times allowed to Mode 2 of 7 hours, to i-Mode'3 of 13 hours, and to Mode 4 of 37 hours. Present provisions require the unit to be in Hot Standby within 6 p hours and in Cold Shutdown within the following 30 hours. The ISTS requires the unit to be in Mode 2 (Startup/ Hot Standby) within 7 hours, Mode 3 (Hot Shutdown) within 13 hours and Mode 4 1 (Cold Shutdow) within 37 hours. This change will relax present shutdown provisions since Mode 2 can be entered at less than 4 approximately 15% rated thermal power whereas present requirements to be in Hot Standbv would require the unit to be less than or e equal to 1% rated therm 1 power within 6 hours. This is offset by a more restrictive requirement to be in Mode 3 in 13 hours. The proposed changes will permit the shutdown to proceed in a more f orderly and controlled manner. This reduces thermal stresses on components of the rector coolant system and the potential for a plant upset that could challenge safety systems under conditions to which this '~ S>ecification applies without significantly increasing risk. Thus, this c tange-is acceptable. L2 Present BFN Technical Specifications do not contain the provisions of LCO 3.0.5 from NUREG-1433. LCO 3.0.5 is added to provide an exception to LCO 3.0.2 for instances where restoration of inoperable equipment to an operable status could not be performed while continuing to comply with required actions. Many Technical Specifications actions require an inoperable component to be removed from service, such as maintaining an isolation valve cLsed, disarming a control rod, or tripping-an inoperable instrument channel. To allow performance of Surveillance Requirements to demonstrate the operability of the equipment being returned tc service, or to demonstrate the operability of other equipment which otherwise could not be performed without returning the equipment to service, an exception to these required actions is necessary. LC0 3.0.5 -is necessary to establish an allowance that, although informally utilized in restoration of inoperable equipment, is not formally recognized in the present Technical Specifications. Without this. allowance certain components could not be restored to operable t status and a plant shutdown would ensue. Clearly, this is not the intent or desire that the Technical Specifications preclude the return r BFN-UNITS 1, 2, & 3 5 of 6 Revision 2 . ~......., n n n, a.. -a

JUSTIFICATION FOR CHANGES SECTION 3.0 - LC0 APPLICABILITY IEC W ICAL CHANGE - LES$ RESTRICTIVE (continued) to service of a suspected operable component to confirm its operability. This allowance is decced to represent a more stable, safe operation than requiring a plant shutdown to complete the restoration and confirmatory testing. L3 The sentence "If a Completion Time requires periodic performance on a 'once per...' basis, the above frequency extension applies to each performance after the initial performance" is proposed to be added. This providas the consistency in scheduling flexibility for all performances bi periodic requirements, whether tney are surveillances or required actions. This change is acceptable since the intent remains to perform tha activity, on the average, once during each specified interval. I l l BFN-UNITS 1, 2, & 3 6 of 6 Revision 2 I

_j .e ~=- _-- BROWNS FERRY NUCLEAR PLANT. IMPROVED TECliNICAL SPECIFICATIONS - SECTION 3.0 ' LIST OF REVISED PAGES NUREG 1433 BWR/4 STS MARKUP. - l t I Replaced page 3.0-2 (page 37 of 478) Revision 1 with page 3.0 2 (page 37 of 478) Revision 2 : Replaced page 3,0 3 (page 38 of 478) with page 3 0-3 (page 38 of 478) Revision 2 -

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NY.h LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 Specification shall not prevent changes in MODES or other (continued) specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the , unit. Exceptions to this Specificat_ ion are stated in the individual Specifications iThe e exc ptions allow en ry (in MOU or o her sp ified onditt ns in he licab 11ty en th associ ted AC IONS be ent red a low u it op ration n the E or ther pecifie I ondi on in he App icabill y only for a limited erio of LCO 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, and 3. Revie.rer's Note: LCO 3.0.4 has been revised so that changes in MODES or other specified conditions in the Applicability that are part of shutdown of the unit shall t be g prevented.

n add ion, LCO 3.0.4 has been rev v so that it is only applicable or entry into a MODE or oth specified condition in e Applicability in MODES 2, and 3.

The MODE ch ge restrictions in LCO 3.0. were pr tously applicable in al MODES. Before this versio of LCO 0.4 can be implemented a plant-specific basis, t iteens must review the existi technical specifications to dete ne where specific restris tons on MODE changes or Required ions should be included individual LCOs to justify this hange; such an evaluation hould be summarized in a matrix o 11 existing LCOs to fact tate NRC staff j review of a con sion to the STS. / LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely t erform testing required to demonstrate its OPERABILITY,4, OPERABILITY of other ofkaichl' equipment. This is an exception to LCO 3.0.2 for toe system returned to service under administrative control t orm 6 theQesting)requirepei.n,:trat: 0^EcACILIT j ster frer PAGE_31 OF N L (continued) """/" ;TS 3.0 2 RT! !. 04/P H -

Z~K f C V. $ l LCO Applicability 3.0 i 3.0 LCO APPLICABit.lTY (continued) LCO 3.0.6 When & ",Jpported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not reqJired to be entered. Only the support system LCO

• ACTIONS are required to be entered.a This is an exception to hhLCO 3.0.2 for the supported systemLFin this event, addit 4+nel evaluationta#d Jimitarte nWtg rgq(i in accordance with Specificattop 5. W. W "Sa"ety function Determination Program (SFDP)."

If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a sup> ort system's Required Action directs a supported system to se declared inoperable or directs entry into Conditions and Required Actions for a supported system, the appitcable Londitions and Required Actions shall be entered in accordance with LCO 3.0.2. db// 6e pcWe) LCO 1.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other.pplicable Specifications. PAGE 1 R swag--sts 3.0-3 "= 1. C4/0'/"b

IIROWNS FERRY NUCLEAR PLANT. IMPROVED TECilNICAL SPECIFICATIONS SECTION 3.0 LIST OF REVISED PAGES NUREG 1433 DWR/4 STS BASES MARKUP Replaced page B3.0 7 with page D3.0 7 Revisica 2

~ R ev. R ' l LCO Applicability B 3.0 BASES the applicable Required Action (s)) to allow the performance LCO 3.0.5 (continu d of t nstr et '4 "6"d The OPERABIL TY of the equipment being returned to fe , a. service; or TheOPERABILITYofotherequipmenh b. The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the fr /A '. AC110 tis is limited to the time absolutely necessary to i I perforWHwed-This Specification does not

1. prcyth time to perform any other preventive or corrective tyled tot

,g f maintenance. 3 gg,yr,A IN An example of demonstrating i e OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comp 1 Actions and must be reopened to perforia the@1with 1 An example of demonstrating the OPERABILITY of other equiment is taking an inoperable channel or trip system out ) of tie tripped condition to prevent th trip function from occurring during the performance of _on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of another channel in the same trip system. LCO 3.0.6 establishes an exception to LCO 3.0.2 -f;r appert LCO 3.0.6 cy:t;;; th:t h m r LCO g rifi;J in Um ieunniui kr!ficetie,,e 'TSv This exception is provided because p m u 3.o.z would require that the Conditions and Required du

• s*Pt**

Actions of the associated inoperable supported system LCO be f 59b Ato '8 entered solely due to the inoperability of the support d d s.lely l system. This exception is justified because the actions An. 4.. urtd in a 5 54 Sto ad ', that are required to ensure the plant is maintaine C0's h-w. d safe condition are specified in the support syste ~ 5 Required Ac' ions. [These Ktqulf ACLlons may %nCluce Fente he suppor ystem's C itionsandRguired Action may spect ther Require Actions. m (continued) 3"Pv't STS B 3.0 7,, <) n y 3v ' 0i/07/05-

4 BROWNS FERRY NUCLEAR PLANT. IMPROVED TECIINICAL SPECIFICATIONS SECTION 3.0 LIST OF REVISED PAGES JUSTIFICATION FOR CilANGES TO NUREO 1433 Replaced pages l1 of 2 through 2 of 2 Rnision 1l with pages [l of 3 through 3 of 3 Rnision 2] ....w ..,y.

l i i JUSTIFICATION FOR CHANGES TO MUREG 1433 SECTION 3.0 - LC0 APPLICABILITY ORACKETED PLANT SPECIFIC 1MFORMAT10N ,7 B1 Brackets removed and correct plant pressure used. llQtL-BRACKETED PLANT SPECIFIC CHANGE 1 P1 NUREG-1433, Revision 1, Reviewers note deleted. The proposed BFN Specifications and Bases for LCO 3.0.4 and SR 3.0.4 include the NUREG-1433, Revision 1 change (BWR26, Cl) which makes LCO 3.0.4 and SR 3.0.4 only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, and 3. This change was determined to be acceptable after review of each of the BFN ITS. This review determined that the ACTIONS of the individual Specifications sufficiently define th remedial measures to be taken (i.e., the ACTIONS to be entered require "Immediate" exit from the Applicability which is judged to preclude intentional entry into that A)plicability regardless of the requirements of LCO 3.0.4 and SR 3.0.4, t1e ACTICAS permit continued operation in that Applicability, or the shutdown into the Applicability requires continuation of the shutdown). The review, done in accordance with the Reviewer's Note, did not identify any required changes to the individual Specifications in Sections 3.1 through 3.10. As a result, these changes do not represent a significa-t impact to safety. P2 Typographical / grammatical corrections made as necessary. P3 The plant specific ITS numbering and example have been used. l P4 Deleted. P5 First sentence indicates exception is for the support system which is incorrect. The first sentence is being replaced with: "LCO 3.0.6 establishes an exception to LCO 3.0.2 when a supported system LCO is not met solely due to a support system LCO not being met' to clarify exception is for *he supported system. P6 Last sentence of 1st paragraph and first two sentences of second paragraph were deleted. This information is better presented in other locations already in the Bases. BFN UNITS 1, 2, & 3 1 of 3 Revision 2

) 3 JUST!Fic.ATION FOR CPJutGES TO NURES 1433 SECY10N 3.0 - LC0 APPLICABILITY NON.gpp vrTED PLANT SPECIFIC CHANGES (continued) l P7 Deleted. P8 Lead in words added to clarify what requires cror.s division checks (i.e.,SFDP). P9 Incorporated Generic technical specification task force item TSTF-104. This change removes the additional discussion provided in LCO 3.0.4 with respect to the use of exceptions and provides the necessary discussion in the Bases. This change provides consistency with LCO 3.0.3 by moving j the discussion of excepttons from the LCO to the Bases. In addition, this change rsduces the potential fer confusion by revising the discussion to eliminate the repeated use of the phraso " Modes or other specified conditions in the Applicability" to increase clarity. 1 P10 Incorporated Generic technical specification task force item TSTF 122. This change revises LCO 3.0.2 Bases to remove possible cor. fusion. The original wording is confusing in that it begins to discuss inoperability of redundant equipment without introducing the topic. This topic of inoperable redundant equipment seen: to be more appropriate for the but an appropriate discussion is already provided Bases of LCO 3.0.3,d wording retains the intent while presenting the there. The propose material in the appropriate context of LCO 3.0.2. Incorporated Generic technical specification task force item TSTF-8. P11 This change revises the Bases for SR 3.0.1 to clarify that credit may be l taken for unplanned events to satisfy any SR, not just those in Section i 3.8, " Electrical Power Systems". This change eliminates th2 potential confusion that may arise with respect to the application of an unplanned event which satisfies the requirements of a given SR by including a discussion in the Bases of SR 3.0.1. P12 Incorporated Generic technical specification task force item TSTF-165. This change revises the Bases for LCO 3.0.5 to use the word ' testing" instead of the acronym "SR." While LCO 3.0.5 refers to " testing ' the l Bases for LCO 3.0.5 inconsistently uses the tem 'SRs* instead of " testing." This change corrects this inconsistency. This change addresses testing that is required to demonstrate OPERABILITY that is not a surveillance. For example, post maintenance testing required to demonstrate OPERABILITY may not be a Surveillance. p BFN UNITS 1, 2, & 3 2 of 3 Revision 2

i l JUSTIFICATION FOR CHANSES TO NURES 1433 SECTION 3.0 - LC0 APPLICABILITY NON-BRACKETED PLANT SPECIFIC CHANGES (continued) P13 Incorporated Generic technical specification task force item TSTF-166. This change revises LCO 3.0.6 to explicitly require an evaluation per the Safety Function Detemination Program. Delete statement ' additional ... limitations may be required" from LC0 3.0.6. This change corrects an inconsistency between LCO 3.0.6 and the LCO 3.0.6 Bases. As currently written, the LCO does not explicitly require an evaluation in accordance with the SFDP, rather it states that additional evaluations may be required. Both the SFDP and the LCO 3.0.6 Bases state that upon entry into LCO 3.0.6, an evaluation shall be made to determine if a loss of safety function exist. In addition, because LCO 3.0.6 states that the evaluation be done in accordance with the SFDP and the SFDP states that other appropriate actions may be taken, there is no need for the statement " additional... limitations may be required" in LCO 3.0.6. i BFN UNITS 1, 2, a 3 3 of 3 Revision 2

..0 lTS Section 4.0 Design Features t Enclosure Contents Enclosed? Response to NRC questions. Yes Summary Description of ITS/ITS BASES Changes. Yes ITS Revised Pages. Yes ITS BASES Revised Pages. . N/A CTS Markup Revised Pages. Yes Justifications for Changes to CTS (DOCS) Revised Pages. ................. Yes NUREG-1433 BWR/4 STS Mark-up Revised Pages. Yes NUREG-1433 BWR/4 STS Bases Mark-up Revised Pages .N/A Justification for Changes to NUREG-1433 (JDs) Revised Pages Yes No Significant Ha::ards Considerations Revised Pages N/A Cross-Reference Matrix Correlating Changes Between the CTS, ITS, and NUREG-1433. Yes l l l l l l l l

t Response to NRC Questions ITS Section 4.0 l s 4.0.1 NRC Change /D//ference statement: CTS 5.1 lists the minimum di:.tance from the outside of secondary containment to the exclusion area boundary as 4000 feet. ITS 4.1 states, "... The distance from the plant stack to the site and exclusion area boundaries as 1465 meters. There is nojustification for changing the minimum l distance from feet to a distance in meters or changing the endpoint from the outside of secondary containment to the plant stack. NRC Comment Providejustification for making changes. Response: BiH ITS Section 4.1 has been revised to be corsistent with CTS 5.1. This change will address the NRC question. Associated DOC M1 has been deleted. 4.0.2 NRC Changc/D//ference statement: ITS 4.3.3 states,"... the opent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 3476 fuel assemblies..." The STS has been indicated. ". a storage capacity limited to no more than 3471 fuel assemblies." Which number tsf fuel assemblies is correct for BFN7 What is the technical basis for the limit of fuel assemblies? NRC Comment: Provide discussion and justification for the more restrictive change. Response: There was a typographical error in the ITS submittal. Capacity of spent fuel storage racks should have been listed as 3471 as indicated in BFN Unit 2 & 3 CTS htarkups, ISTS NUREG htarkup, and UFSAR section 10.3. This has been corrected. Also, DOC M3 has been revised to provide additional discussion on the more restrictive change. 4.0.3 NRC Change /Di[/crence statement: CTS 5,5.C prohibits ",, loads greater than 1000 pounds shall not be carried over spent fuel assemblies stored in the spent fuel pool." This requirement is moved to plant procedures. The procedures and the controls over the changes to this requirement are not identified. NRC Comment: Provide discussion and justification for moving this requirement. Response: CTS DOC LA2 has been revised to indicate that this requirement has been moved to the Technical Requirements hianual(TRht). This type of requirement is not required to be in TS using the guidance in 10 CFR 50.36. Changes to the TRh1 will be controlled in accord nce with 10CFR50.59. Pagei

O 4.0.4 NRC Change /D/fference statement STS 4.3.1.lt, and 4.3.1.2a require fuel storage racks be designed with ".. fuel assemblies having a maximum [k infinity of ~ [1.31] in the normal reactor core configuration at cold conditions] [ average U 235 ( enrichment of[4.5] weight percent];..." The justification states, ".. The proposed new limitation is a fuel design feature and not a design feature of the rack.." The justification does not discuss system design and operational constraints that preclude adopting these STS requirements. NRC Comment: Provide discussion and justification for the STS deviation based on system design and operational constraints. Response: The CTS has been revised to incorporate the STS requirement of" fuel assemblies having a ma).imum k infinity of 1.31 in the reactor core configuration at cold conditions" with the following BFN specific values. For the high density storage racks, the appropriate k infinity is 1.33. For the new fuel racks,1.31 is correct. Justification P2 has been revised accordingly on this change. Justification has been provided in P2 for not including STS provisions for "[ average U-235 enrichment of[4.5] weight percent]". This value is not currently in CTS, and, as explained in P2, TVA does not consider it necessary to add this new provision. \\lifngu24tatajickun,ists'oulvmtala10_44 tai 4 0 skw Page 2

I Summary Description of ITS/ITS Bases Changes ITS Section 4.0 ITS 4.1 In response to an NRC comment, the ITS site location description was revised to better match the existing current TS description. ITS 4.3.1.1 and 4.3.1.2 In response to an NRC comment and to maintain consistency with NUREG-1433, new ITS provisions 4.3.1.la and 2a were added which address the maximum design k-infinity of fuel assemblies to be stored in the spent fuel and new fuel storage racks. These changes are consistent with the BFN licensing basis for the storage racks and fuel design, the General Electric Standard Application for Reactor Fuel and fuel storage requirements. ITS 4.3.3 Corrected typographical error (3476) for spent fuel pool fuel assembly storage rack capacity value. The correct value is 3471. r

t !!ROWNS FERRY NUCLEAR PLANT lMPROVED TECHNICAL SPl:CIFICATIONS SECTION 4.0 LISTOF REVISED PAGES UNIT I ITS SECTIONS Replacd page 4.01 with page 4.01 *RI Replaced page 4.0 2 with page 4.0 2 *RI b v yv..- -ye-

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site location The BFN site contains a> proximately 840 acres and is located on the north shore of Wheeler.ake at Tennessee River Mile 294 in Limestone County, Alabama. The minimum distance from the outside of the secondary containment butiding to the Loundary of the exclusion area as defined in 10 CFR 100.3 is 2,4000 feet. 4.2 Reactor Core 4.2.1 fuel Assemblies The reactor shall contain 764 fuel assemblies. Each assembly shall consist of a matrix of Zircalloy fuel rods with an initial composition of natural or slightly enriched urantos dioxide (00,) as fuel material, and water rods. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with NRC staff approved codes and methods and have been shown by tests or analyses to comply with all safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in ncnlimiting core regions. 4.2.2 Control Rod Assemblies The reactor core shall contain 185 cruciform shaped control rod assemblies. The control material shall be boron carbide, hafnium metal, or bcth, as approved by the NRC. 4.3 Fuel Storage 4.3.1 Criticality + 4.3.1.1 1he spent fuel storage racks are designed and shall be maintained with: (continued) 8FN UNIT 1 4.0-1 Amendment *RI

i Design Features 4.0 4.0 DESIGN FEATURES 4.3 Fuel Storage (continued) a. Fuel assemblies having a maximum k-infinity of 1.33 in the normal reactor core configuration at cold conditions l b. k,,, s 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 10.3 of the FSAR; and l c. A ncminal 6.563 inch center to center distance between fuel assemblies placed in the storage racks. 4.3.1.2 The new fuel storage racks are designed and shall be maintained with: a. Fuel assemblies having a maximus k-infinity of 1.31 in the normal reactor core configuration at cold conditions l l b. k,,, s 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 10.2 of the FSAR; l l c. k,,, s 0.90 if in a dry condition, or in the tbsence of moderator, as described in Section 10.2 of the l FSAR; and l l d. A nominal 6.625 inch center to center distance between fuel assemblies placed in storage racks. 4.3.2 Drainnae The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 640 ft. 4.3.3 Capacity The spent fuel storage pool is designed and shall be maintained l with a storage capacity limited to no more than 3471 fuel assemblies. i BFN UNIT 1 4.0-2 Amendment *RI

l l BROWNS FERRY NUCLEAR PLANT IMPROVED TECilNICAL SPECIFICATIONS SECTION 4.0 t' LIST OF REVISED PAGES UNIT 2 ITS SECTIONS Replaced page 4.01 with page 4.01 'RI l Replaced page 4.0 2 with page 4.0 2 'R1 i i ? k k i /

Design Feature 400 4.0 DESIGN FEATURES 4.1 Site Location The BFN site contains a> proximately 840 acres and is located on the 1 north shore of Wheeler.ake at Tennessee River Mile 294 in Limestone County, Alabaana. The minimum distance from the outside of the secondary buildinfi to the boundary of the exclusics area as defined in 10 CFR L00.3 is 1 4000 feet. i 4.2 Reactor Core 4.2.1 Fuel Assemblies The reactor shall contain 764 fuel assemblies. Each assembly shall consist of a matrix of Zircalloy fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U0,) as fuel material, and water rods. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel l designs that have been analyzed with NRC staff approved codes and methods and have been shown by tests or analyses to comply with all safety design bases. A limited number of lead test assemilies that have not completed representative testing may be placed in l r.:nlimiting core regions. 4.2.2 Control Rod Assemblies The reactor core shall contain 185 cruciform shaped control rod assemblies. The control material shall be boron carbide, hafnium metal, or both, as approved by the NRC. l 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with: l (continued) e BFN UNIT 2 4.0 1 Amendment *R1

Design Features 4.0 4.0 DESIGN FEATURES 4.3 Fuel Storage (continued) a. Fuel assemblies having a maximus k-infinity of 1.33 in the normal reactor core configuration at cold conditions l b. k,,, s 0.95 if fully flooded with unborated water, which includss an allowance for uncertainties as described in Section 10.3 of the FSAR and l c. A nominal 6.563 inch center to center distance between fuel assemblies placed in the storage racks. 4.3.1.2 The new fuel storage racks are designed and shall be maintained with: a. Fuel assemblies having a maximus k-infinity of 1.31 in the normal reactor core configuration at cold conditions l b. k, s 0.95 if fully flooded with unborated water, which includes en allowance for uncertainties as described in Section 10.2 of the FSAR; k.,, s 0.90 if in a dry condition, or in the absence l c. of moderator, as described in Section 10.2 of the FSAR and l d. A nominel 6.625 inch center to center distance between fuel assemblies placed in storage racks. I 4.3.2 Drainaat The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool balow elevation 640 ft. 4.3.3 Capacity The spent fuel storage pool is designed and shall be maintained l with a storage capacity limited to no more than 3471 fuel assemblies. BFN UNIT 2 4.0-2 Amendment *R1

~ ..,.. _.~ -...-.-.~...._... -.. -...-. d - bKOWNS FERRY NUCLEAR PLANT IMPROVED TECHNICAL SPECIFICATIONS SECTION 4.0 LIST OF REVISED PAGES UNIT 3 ITS SECTIONS' . Replaced page 4.01 with page 4.01 *RI - j Replaced page 4.0 2 with page 4.0 2 'R1 l . j I ' } - 1 i h t l~ l i i' h l 1. t i t I i Y 1 I-y t -l er r- - f l' .1 ,..a.-,..-.-.---.,-,.... .r. . r e,--- _..,-.. ;,. _. _, ~ - - - - -.. ~..

Design FOatures 4.0 4.0 DESIGN FEATURES 4.1 Site Location The BFN site contains a) proximately 840 acres and is located on the north shore of Wheeler Lake at Tennessee River Mile 294 in Limestone County, Alabama. The minimus distante from the outside of the secondary containment building to the boundary of the exclusion area as defined in 10 CFR 100.3 is 1 4003 feet. 4.2 Reactor Core 4.2.1 fuel Assemblies The reactor shall contain 764 fuel assemblies. Each assembly shall consist of a matrix of Zircalloy fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U0,) as fuel material, and water rods. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with NRC staff approved codes and methods and have been shown by tests or analyses to comply with all safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions. 4.2.2 Control Rod Assemblies The reactor core shall contain 185 cruciform shaped control rod assemblies. The control material shall be boron carbide, hafnium metal, or both, as approved by the NRC. 4.3 Fuel Storage 4.3.1 _ Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with: (continued) t I BFN-UNIT 3 4.0-1 Amendment *R1

Design Features 4.0 4.0 DESIGN FEATURES 4.3 fuel Storage (cortinued) a. fuel assemblies having a maximus k-infinity of 1.33 in the normal reactor core configuration at cold l conditions l b. k,,, s 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 10.3 of the FSAR 3nd l c. A nominal 6.563 inch center to center distance between fuel assemblies placed in the storage racks. 4.3.1.2 The new fuel storage racks are designed and shall be a:3intained with: 8 a. Fuel assemblies having a maximus k-infinity of 1.31 in the normal reactor core configuration at cold conditions b. k,,, s 0.95 If fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 10.2 of the FSAR; k, s 0.90 if in a dry condition, or in the absence l c. of moderator, as described in Section 10.2 of the FSAR and l d. A nominal 6.625 inch center to center distance between fuel assemblies placed in storage racks. 4.3.2 Drainnae The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 640 ft. 4.3.3 Capacity The spent fuel storage pool is designed and shall be maintained l with a storage capacity limited to no more than 3471 fuel assemblies. BFN UNIT 3 4.0-2 Amendment *R1

4 i o l !!ROWNS FERRY NUCLEAR PLANT. IMPROVED TECilNICAL SPECIFICATIONS SECTION 4.0 LIST OP REVISED PAGES j UNIT I CURRENT TECIINICAL SPECIFICATIONS MARKUP Replaced page 2 of 4 (page 5.01) with page : of 4 (Page 5.01) Rnision i Replaced page 3 of 4 (page 5.0 2) with page 3 of 4 (Page 5.0 2) Rnision 1 Replaced page 4 of 4 with page 4 of 4 Resision I m

Rev.I 5Rc He w.,, u.o 4.0

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^ ^ _. n -_...., ^ " i: in. ^ 4. _.,..._ _ '., ?- -- __ ; _ = - -. Thesite " ' --in ;'impprezimately 840 seres q // h./ the north shore of Wheeler Lake at T i ee River Nile 294 a [as "*J \\ _. j@ Limestone County, A2abana. N istance from the ^ l W r :'f: ef & :: _ ^ ^ _.... R~ _. 2 7,besde

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__-- ^ i " ** L p SM M ^ !..-' -- _ = is = ?^^ _ ' ^ ^ ^ '::. 44 l% ",, ;..;. 7., __. f. _.- f'1,' ab = ~ i- - [ t 't : =..a.; ; fm ,__um 2 - M T g t.s; fy D--M -g N reacter shall contain 764 fuel semblies. Each I2'I 4 assembly shall esasist of a matriz e sesese6es>4Mer fuel rods with as taltial ceapositism of natural er siishtly unriched uranium disside (90 ) au fuel material and water 2 rods. Lialted substitutions of sitcoat s alley or stainless steel filler rods for fuel reds, in accordance with approved applications of fuel red configurations, may be used. Fuel assemblies shall be limited to these fuel deaisas that have been analysed with NBC staff approved codes and methods and have been sheva by tests or analyses i to esaply with all safety desisa bases. A limited a mber of leed test assemblies that have met completed representative testing may be placed la nemlimiting core ,e..as. g 4, A2 #.' N reacter core shall contain 185 crucifera shaped centrol red as os. The centrol material shall be bores carbid am W hatai n met as approved by the Ntc. d* 8 573 ItacTOR mt The easter vessel shall be as de cribed in Table 4.2-1 of h appl able desisa e a shall be describ in fa le 4.2-1 of FSAR. 5.4 MTAIMEErf A. The pr ipal design y aseters for a prima oestat t shall be given in T le 5.2-1 the AR. Na 11 cable desi codes shall as deser bed i Secti 5.2 of the B. N seeendary containment shall %e as descri ed in Section 5.3 of the ySAR. LAI AMDf06 NO. Igg 7 _DF syn 5.0-1 PAGE~ Unit 1

__ _ _ _ _ _ _ ____ _._ _. _.- ___~_ feV. I h StuiC:u4.;m 4.0 h RLaan nRSIEE FEAftFRES (Cestissed) N 2 1 III3 y,o .5.4 (Continu Q C. trati to the ry contai t and p as pa ing i ush such strati shall be d igned in rdane j vi the standa set to in Section 2.3.4et j i FSAR. h A3 f.),t The arrangement of fuel in the new-fuel storage facilit l 4'8.8.1 N bi' shall be such that k.,,, for_ dry eenditions, isrir:: r-s 0.90 and fleeded isP 95 (Section 10.2 of F8AR). f of the spent fuel storage peel shall be less than The k,g er equa to 0.95. g e iss t est Einc DMIsl 5.6 stati class I struct es /- - [ - ve been designed to that a des basis at with eund seet erati of 0.2. The o rational asis rth used in plant esign suned a ground ace 1 erat of 0. (see ) r (Secties 2.5 of the ). j hTASE AT 4.3.2 + 4.3, PAh: M" trW 5.0-2 Unit 1

M INSERT 4.3.1 ) 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with: I q fjtJ 4,')./,l.4 [ 4.' A nominal 6.563 inch center to center distance between fuel assemblies placed in the storage racks. 4.3.1.2 The new fuel storage racks are designed and chall be maintained with: N ### A no"inal 6.625 inch center to center distance ftNTEXTV.3/ Rd between fuel assemblies placed in storage racks. J r JNSERT4.3.2 4.3.2 Drainaae The spent fuel storags pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 640ft. INSERT 4.3/3 4.3.3 (anacity The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than44M-fuel assemblies. Jy7/ 'E N S E A T y. S I.I.A fIU M. f'1e. I A rtem bl**e r l win; A n ulmnm A !nf/ns'ty togt., in rf < n,ma I n<,ep - c.,ce ein f ty c.,qAIt:nf rRSEC 4.3.t.'A.n A S c( A tre.if/t< r 4avi,y < ma:nc k infis:ty a f t.3/ t c./g in t < q. <m< l <- e<c yas c..<e. c m ftp,,pt., 4 A one p:en r 8FM & "f 4 m,:t]

BROWNS FERRY NUCLEAR PLANT. IMPROVED TECHNICAL SPECIFICATIONS SECTION 4.0 LIST OF REVISED PAGES UNIT 2 CURRENT TECHNICAL SPECIFICATIONS MARKUP Replaced page 2 of 4 (page 5.01) with page 2 of 4 (Page 5.01) Rnision 1 - Replaced page 3 of 4 (page 5,0 2) with page 3 of 4 (Page 5.0 2) Rnision i Replaced page 4 of 4 with page 4 of 4 Rnision 1 h <l f' T

Ru. I cm,4%% an M.I. e>-mueenzaram rzAmms MKf211993 @, _y:I .s.k t... A, -,_ m., 1 / tr- " r -'t 2 i; an;;;d :: 5:: 1-N = h 1==* Plant [

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The# rite '-?! ::--!:t -ffpproximately e=v acres,an the north shore of Wheeler Lake at Tgessee River Mile 294 IF l l Limestone County, Alabama. The ci ' distance from the Q

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.L... _:=., ;. ;e _; L.014 0.,., J - bonda 540 4(:" t- --=? m!- 1: = = o 1 d1. 1;.. 1&&.^ [ "." L l': JJ i'YT,,c7 O k ?, k;}, ' T : h. R.h ! A - - ~ ~ m nw- : : :, ;,, 4 ;. Q~n - - - W %r;- y a;, ~ ~ = emblies. Each h f,(g. The reactor shall contain 764 fuelassembly shall consist of a matr rods with an initial composition of natu.-al or slightly enriched uraalima dioxide (00 ) as fuel asterial and water 2 rods. Limited embstitutions of airconium alley or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel red configurations, may be used. Feel aseeablies shall be limited to those fuel designs that have been analysed with ERC staff approved codes and authods and have been shown by tests or analyses to comply with all safety design bases. A limited number of Isad test assemblies that have met completed representative testing may be placed in nonlimiting core regions. t / t/.2 2. V The reactor core shall contain 185 crucifors shaped e strol rod assemb es. The control material shall be l boren carbid eaddee hafnium met as a roved by the Etc. t 3 (5.3 RIACTot itsSEL essel shall be as described in Table 4.2-2 of the Tue reactor FSAR. The applicable design codes shall be as described in l Table 4. 1 of the FSAR. j 5.4 $0NTA A. The principal design arameters for the primary containment shall b as given in Table 5.2-1 of a FSAR. The applicable de sa codes shall be as descri ed in Section 5.2 of a FSAR. I S. The secoadary containment shall be as descrJ'oed in Section 5.3 of the F8AR. LM AMmDNER NO. 215 gg 5.0-1 2 OF h Unit 2 PAGE 1 _ _ _ _, _ ~ - _ - _ _

f ed. $ Cyd.ek % M anteen nasim FIAftrnas (Contimmed) MRy 211993

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,A: 54 CDETAI M kT (Continues) ] C. anstrations the primary een t and pipi passing such trations aball be in acco see with standa t forth in Section 5.2.3.4 of the g AR. Gb, e. 8 434 T arrangapaat of fuel in the mov-fuel storage facili shall be such that k.,o for dry conditions, is {rr5 M j I 5 (section 10.2 of FSAE). l h.90 and flooded is _::: O A3 a./.// Qpp DC The k,gf of the spent fut. storage pool shall be less than f swrew or equal to U.95. 4.11 'C. greater than \\' @ d in the spent fuel pool. aball g t be capriod av 1 k a fuel assemblied store 6 nirisurc n-=1 - stattom class'I structures and systems have been desismed { to thstand a design earthquaka with gr } accel ties of 0.23 Ths rational basis earth used in the y t design assumed a eund acceleraties of (see Section 2.5 the FSAR). 9 MS NMf M t. 2 4 6/.8.3, + e s AMENDMENT N0. 215, PAGE 3 OF L sFN 5.0-2 Unit 2

Re.v. I i N 1NSMT'4.3.1 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with: F .Af.' A nominal 6.563 inch center to center distance L.INJE4r 4 31.lA between fuel assemblies placed in the storage racks. 4.3.1.2 The new fuel storage racks are designed and shall be maintained with: pggg yj, M A nominal 6.625 inch center to center distance between fuel assemblies placed in storage racks. IM$DtT._4.3.2 4.3.2 Drainacg MS The spent fuel storage pool is designed and shall be maintained to-prevent inadvertent draining of the pool below elevation 640ft. INSE2T4.3f'3 4.3.3 Canacity The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 3471 fuel assemblies. [NS(l{ Y 'l.3.1.I. A A. 6.( < gjen 6lle; lMiny A h4/imsm k Inflelfy a f /.3$ o'n T(' n * *ma l ren e f c s "<. C e n f*ty e4 j.,, my coff

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IIROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS SECTION 4,0 LIST OF REVISED PAGES UNIT 3 CURRENT TECHNICAL SPECIFICATIONS MARKUP Replaced page 2 of 4 (page 5.0-1) with page 2 of 4 (Page 5.0-1) Revision 1 Replaced page 3 ef 4 (page 5.0 2) with page 3 of 4 (Page 5.0-2) Revision 1 Repla:cd page 4 of 4 with page 4 nf 4 Revision I

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. ;,,,;; e! -2 "i. \\ The/e_,ite ;.11 nxi;; ;f ,m (f3MTGlpproximately 340 acreskon the north shore, of Wheeler Lake at Tennessee River Mile 294 in Limestone County, Alabama. The i distmace from e rid: ;f. .t.. n::r'--- t r'- * - * .g ter 5f*I N abounda f i t e.:: i r i n u n : f '!::f 1i (m. " - /E3 10 S l'^ &. T Mfyp ^,"^0 f:::. A O i. h E.-5 W % art s < M.; u.u. J: 3 L T J ' ' 3 " " *

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" ~ -E ~"~'",'-V 4 2,& bre. 3N# 426 cloy V,2. The reactor shall contain 764 fuel asoamblies, sa assembly shall consist of a matrix ofLs&esen&en.-enor fuel rods with an initial composition of natural or slightly striched uranium dioxide (UO ) as fuel material and water 2 rods. 1.ialted substitutions of sitconium alley or stainless steel filler rods for fuel rods, 12 accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with NRC staff approved \\ codes and methods and have been shown by teste or analyses to comply with all safety design bases. A limited number of lead test assemblies that f. ave not completed j representative testing may be placed in nonlimiting core regions. 4,2 2 The reactor core shall contain 185 eruciform shaped centrol red assemblies. The control material shall be beren carbid hafniusmeta(asapprovedbytheNRC. h % musefot VEsstL The reacto vessel shall as described in Table 4.2-2 of the FSAR. applicable de ign codes sha i be as described h Table 4. -1 of the 5.4 ""TA i - -1 A. principal esign paramete a for the prima chatainment 11 be as giv in Table 5.2-1 f the FSAR. The applica e design code shall be as dose bed in Section 5. of the FSAR. 3. The seco ary contains t shall be as des ribed in Section 5.3 of the FSAR. h b OF PAGE_ M W N NO. I 7 1 Br3 5.o-1 Unit 3

feV.[ F d--meestasumuzmust (Conti==.d> - 9a4c.4 4.o 5AY 211993 5.4 (Continued C. ametrati to the rimary con t and p ing passing so penetrat shall be igned in cordance et res set rth in Secti 2.3.4 o the e x -g,._ y3. erwan The arrangement of the fuel in th's new-fuel storage V48-K facility shall be such that k,gf, for dry conditions, is Cf1::: "--7 0.90 and flooded iQ/-- -- . 5 (Section 10.2 of rs=>.g Thek,gfofthespentfuelstoragepeelshallbelessthan c9 .r a

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C. greater than pounds shall not carried over J fuel assemblies ored in the spent 1 pool. 6 n iante mercs The tation alass structuras systems have besa d ignedT I to tand a deal basis ear with gr \\ f accel tism of 0.23 operationa is ear quake i in the y t design as a ground acc. ation 0.14 ee (Sectica2.5oftherSH). h rii 4.3.2 + 4,3. a PAGE 3 OF aumwtw n.I n RFR 5.0-2 Unit 3

fed. I 1 INSERT 4.3.1 4.3.1.1 The spent fuel storage racks are designed and shall be maintaired with: ' Imfg U.l.14 g.' A nominal 6.563 inch center to center distance L between fuel assemblies placed in the storage racks. 4.3.1.2 The new fuel storage racks are designed and shall be maintained with: } MfE/g <p"isa 4 A n minal s.625 inch center to c.cnter distance between fuel assemblies placed in storage racks. r INSERT 4.3.2 4.3.2 Drainaae M3 The spent fuel storage pool is designed and shall be maintained to. prevent inadvertent draining of the pool below elevation 640ft. INSERT 4.3/3 4.3.3 Caoacity The spent fuel storage' pool is designed and shall be maintained with a storage capacity limited to no more than 3471 fuel assemblies. I N fE4 T </.3././.4 A.fneIesie A <S hany A m;v n k-ln6,o't.1of con f.'y y n N.,

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... ~. -- i BROWNS FERRY NUC8 EAR PLANT. IMPROVED TECHNICAL SPECIFICATIONS - ii SECTION 4.0 LIST OF REVISED PAGES - ,i i _.i JUSTIFICATION FOR CHANGES TO CURRENT. TECH SPECS .j 1 . ' Replaced pages 1,2, and 3 with pages 1,2, and 3 Revision 1 ] I 1 ? i I' i a e d e h -L

e JUSTIFICATIONS FOR CHANGES SECTION 4.0 - DESIGN FEATURES ADMINISTRATIVE CHANGES Al Reformatting and renumbering are in accordance with the BWR Standard Technical Specifications, NUREG 1433. As a result the Technical Specifications should be more readily readable, and therefore, understandable by plant operators as well as other users. The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications. Editorial rewording (either adding or deleting) is done to make consistent with NUREG-1433. During ISTS development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or interpretational) to the Technical Specifications. Additional information has also been added to more fully describe each subsection. This wording is consistent with the BWR Standard Technical Specifications, NUREG-1433. Since the design is already approved, adding more detail does not result in a technical change. A2 The specific zircontam alloy (zircaloy) used for the fuel rod matrix has been provided. A3 The values for K.,, have been changed from "<' to 's." This change is slightly less restrictive but has been categorized as administrative since the s value is consistent with the FSAR and the difference between < and s is insignificant. CTS 5.5.A states that the arrangement of fuel in the new fuel storage facility shall be such that the k,, for dry conditions, is less than 0.90 and flooded is less than 0.95 and l references FSAR Section 10.2. The FSAR states that keff is "not more than 0.90' in one place and "below 0.9' in a dry condition in another. i It also states that it "will not exceed 0.95" when flooded with water. l TECW ICAL CHANGE - NORE RESTRICTIVE The items identified as More Restrictive (MR) are those which contain requirements that are more restrictive than Current Technical Specifications. These MR requirements are based on the Standard Technical Specifications for BWR/4, NUREG-1433, modified to reflect BFN specific design, and have been determined to be appropriate and safe for BFN based on a review of current l design bases. BFN-UNITS 1, 2, & 3 1 Revision 1

JUSTIFICA W M5 FOR CHANGES SECTION 4.0 - DESIGN FEATURES TECHNICAL CHANGE - NORE RESTRICTIVE (continued) l M1 Deleted. M2 The existing Technical Specifications do not contain these limitations on fuel storage in the spent /new fuel storage racks. The addition of these limitations is more restrictive since a formal license amendment will be required to modify design. K3 The existing Specifications do not contain these limitations on fuel storage. The addition of these two Specifications related to spent fuel pool storage design impose restrictions which will require formal license amendment request / approval to modify design. As such, their addition is considered more restrictive. ITS 4.3.2, Drainage, was added to identify the requirement for the minimum elevation of water to be maintained in the s)ent fuel storage pool. This addition makes the ITS consistent with tie guidance provided in the NUREG and is consistent with plant design limitations. ITS 4.3.3, capacity, is consistent with the design basis as described in the UFSA" The design basis includes: the spent fuel storage racks shall bs . plied to accommodate 454 percent of the full core load, or 3471 assemblies; racks shall be designed and arranged so that the fuel assemblies can be efficiently handled during refueling operations; the fuel array in fully loaded spent fuel racks shall be subcritical by a substantial margin; and each rack containing fuel shall be designed to l withstand earthquake loading so that distortion of the spent fuel l storage arrangement will be within acceptable bounds. This addition l l makes the ITS consistent with the NUREG. l i l l l l BFN-UNITS 1, 2, & 3 2 Revision 1 l

JUSTIFICATIONS FOR CHANGES SECTION 4.0 - DESIGN FEATURES TECHNICAL CHANGE - LESS RESTRICTIVE LA1 The description of design parameters of the Reactor Vessel and Containment have Leen removed from Technical Specifications. Seismic Design requirements were also removed. The design parameters are described in more detail in FSAR Sections 4.2, 5.2, and 5.3. The seismic design requirements remain detailed in FSAR Section 2.5. Any changes to these design parameters or requirements must conform to 10 CFR 50.59. Furthermore, suffic;ent detail relating to these features exists in LCOs to ensure any changes which may affect safety would-require prior NRC review and approval. Features (Reactor and Containment) with a potential to affect safety are sufficiently addressed by LCOs. Changes to other features, if altered in accoidance with 10 CFR 50.59, will not have a signif; cant affect on safety, and the criteria of 10 CFR 50.36(c)(4) for inclusion as a Design Feature are not met. Therefore, removing these details from the Technical Specifications, while retaining the detailed descriptions in the FSAR, will not impact the safe operation of the plant. LA2 This requirement is being relocated to the Technical Requirements Manual (TRM). This change maintains consistency between the BFN ITS and the BWR/4 ISTS. Changes to the TRM will be controlled in accordance with 10CFR50.59. BFN-UNITS 1, 2, & 3 3 Revision 1 l

Y i . BROWNS FERRY NUCLEAR PLANT. IMPROVED TECHNICAL SPECIFICATIONS SECTION 4.0 ~ LIST OF REVISED PAGES . i i NUREG-1433.BWR/4 STS MARKUP Replaced page 444 of 478 (page 4.01) with page 444 of 478 (page 4.01) Resision 1 i Replaced page 445 of 478 with page 445 of 478 Revision 1 -.. i Replaced page 446 of 478 (page 4.0-2) with page 446 of 478 (page 4.0 2) Resision 1-i I r i r i i a t J t e r4 .= w --<rw w i.e = w u ce. w r n.+.. w

Rev.I Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site location { Text de;ccipti- ' a ne kc.uun.}t frusca r 3 4. o.s }_, 4.2 Reactor Core h 4.2.1 Fuel Assemblies The reactor shall contain.36ef fuel assemblies. Each assembly shall consist of a matrix of /Zircalloy a- ? rJ.07 fuel rods withh dioxide (U0 ) as fuel material hand water rodsh Limitedan initial c 2 substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with NRC staff approved codes and methods and have been shown by tests or analyses to comply with all safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions. 4.2.2 Control Rod Assemblies Q ~ l8S The reactor core shail contain f4W1 cruciform shaped control rod assemblies. The control material shall be fforon carbide, hafnium metal ved by the NRC, 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel st racks are designed and shall be maintained with: {F assemblies having a maximum ik-infinity f] in the no i rhetor core confhntratio aJ 9dition average %235 enrichment or (do r 5f*I [4.5J weight percent); w$gg 5 0.95 if fully flooded with unborated water, 6/#, k l 8 ich includes an allowance for uncertainties as described in-{'Section Sef of the FSARd and /o. 3 O PAGE 4 N OF (continued). 000/4 STE 4.0-1 Re 1, 01/07/05-

Ru. I O INSERT.4.0 1A The BFN site contains approximately 840 acres and is located on the north shore of Wheeler Lake at Tennessee River Mile 294-in Limestone County, The distance from the 9 er,; steck te ; tie site er4 exci;; Ma =rma 1 Alabama. berMH:: i; 14 5 =iec;. Th; di:t r:: 're ; tie ri.ni aieck te th: ?:e ^^^&t;..... e i s 3:00 ;.;t;r;.,4f3;4,., f f.4 e rec,qA,y c.,at.4 9 3e97 / T t 4. t-h* s 4<'f *f rir TAC btik e c.4 43 4efgeg bst{fIq; ~ t for. 3 in /pcli is.? Y fe<r. O PAGE W5 OF_VN

Design Features 4.0 4.0 DESIGN FEATURES 4.3 Fuel Storage (continued) 6.s43 A nominal 4&&f inch center to center distance c. between feel assemblies placed in the storage racks. 4.3.1.2 The new fuel storage iacks are designed and shall be maintained with: (F el assemb11es lia ing a maximus k-infinity ofN 4. If in the norma reactor core nfigurak on a0 geoid ditionsf/TavMge U-235 enrichment or gy7 [4.5] welght ;Wrcent); b, & k 5 0.95 if fully flooded with unborated water, l w$Nhincludesan7.llownaceforuncertaintiesas O81 describedin8ectionS4. of the FSAR}i-if.T.ede ;;;d by :; : e: fer, d.?ch l

c. g d.

k gs wJ.., ellewance-f: ur. cert:htie ;as @ described in Dection.0d of the FSARWand t o. 2-h4/dAnominal inch center to center distance l between fuel assemblies placed in storage racks.

• d'y ec.4M, oo s. p.e 4.3.2 Drainaae Pi afay, g 4,4 j,_

The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool bslow elevation (.185 ftf. 82-G4 4.3.3 Capacity The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than M fuel assemblies. Je i PAGE W6 OF d BWR/4 5T5 - 4.0-2 3:v 1, 04/07/0 L

.m. ..__..._..~... _ __ _.. .._2._ 3 1 . BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS SECTION 4.0 LIST OF REVISED PAGES - JUSTIFICATION FOR CIMNGES TO NUREG-1433 : Replaced page 447 of 478 Revision 0 with page 1 Revision 1 l

Deleted page 443 of 478 (duplicate of page 447 of 478 Resision 0)

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JUSTIFICATION FOR CHANGES TO NUREG-1433 SECTION 4.0 - DESIGN FEATURES .tRACKETLi PLANT SPECIFIC INFORMATION bl Brackets removed and optional wording preferences revised as necessary to reflect BFN plant e,pecific design. 82 Brackets removed and values revised as necessary to _ reflect BFN plant specific design. HON-BRACKETED PLANT SPECIFIQ CHANGES P1 This specification has not been implemented at BFN and has been revised to reflect the 8FN design basis for the new fuel storage racks under normal dry conditions. l P2 The ISTS states in part that the spent' fuel storage racks and the new fuel storage racks are designed and shall be maintained with fuel assemblies having a maximus k-infinity of 1.31 in the nomal reactor core configuration at cold conditions with an average U-235 enrichment of [4.5] weight percent. For the BFN high density storage racks, the appropriate k-infinity is 1.33. For the-new fuel racks, 1.31 is -correct. The fuel enrichment description is being deleted. This limit is redundant to the limits established in GE's Standard Application for Reactor Fuel (GESTAR) and is, therefore, not included in the ITS. This l -is consistent with the BFN UFSAR. I l f l BFN-UNITS 1, 2, & 3-1 Revision 1

l y JUSTIFICATION FOR CHANGES TO NUREG 1433- .SECTION 4.0 - DESIGN FEATURES BRACKETED PLANT $PECIFIC INFORMATION ' Brackets removed and optional _ wording preferences rev ed as necessary to reflect BFN plant specific design. 82 Brackets removed and values revised as necessary reflect BFN plant -specific design. MON-BRACKETED PLANT $PECIFIC CHANGES P1 This specification has not been implemen d at BFN and has been revised to reflect the BFN design basis for th new fuel storage racks under i normal dry conditions. P2 The fuel storage criticality anal es are based on an assumed k-infinity (not enrichment) which is depen nt on the fuel design being used. For a given enrichment, the maxi k-infinity will change depending on the amount of burnable poison e ained in the fuel assembly. Therefore, ~ specifying a value for k-i inity (or enrichment) would result in a Technical Specification ange to change fuel design. As part of the safety and licensing a lyses for each cycle General Electric verifies that the new fuel me s the fuel storage criticality requirements. The proposed new limit on is a fuel design feature and not a design feature of the ra The limitations and requirements for the type of fuel used is air ady provided in Specification 4.2.1. Therefore, the-addition of a limitation on the maximum fuel k-infinity (or enrichment) ored in fuel racks in Specification 4.3.1 is unnecessary to provide equate margin of safety from criticality and has not been i i included. the proposed BFN ISTS. The details of the criticality analyst are described in the FSAR and do not belong in Technical Specif ations. I. "A l l Os le te this P*$* 0*P of' pag < W 7 of 477. m d PAGE 443 OF L 'BFN-UNITS 1,-2,_& 3 1 Revision 0

- 6'. . BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS : -SECTION 4.0 = i =- LIST OF REVISED PAGES -- j ' BFN UNIT 1,2, and 3 CROSS-REFERENCE MATRIX Innened new page 1 of 1 Raision 0. s I h ( i. L a e .v v , -,w,e-- ,e3-er. y-,.s--+- ,r,-. ,y = w

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